Once-Through Cooling and Closed-Cycle

Program on Technology Innovation: Tradeoffs
Between Once-Through Cooling and Closed-Cycle

Cooling for Nuclear Power Plants
2012 TECHNICAL REPORT
Program on Technology
Innovation: Tradeoffs
Between Once-Through
Cooling and Closed-Cycle
Cooling for Nuclear Power
Plants
This document does NOT meet the requirements of

10CFR50 Appendix B, 10CFR Part 21, ANSI
N45.2-1977 and/or the intent of ISO-9001 (1994).
EPRI Project Manager

D. Bailey
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USA
PO Box 10412
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askepri@epri.com
www.epri.com
1025006
Final Report, June 2012
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Acknowledgments
The following organizations prepared this report:

Electric Power Research Institute (EPRI)
3420 Hillview Avenue
Palo Alto, CA 94304
Principal Investigator
D. Bailey
Maulbetsch Consulting
770 Menlo Avenue, Suite 211
Menlo Park, CA 94025
J. Maulbetsch
EXCEL Services Corporation
11921 Rockville Pike, Suite 100
Rockville, MD 20852
G. Vine
This report describes research sponsored by EPRI.
The input and review support on cooling water issues by the
Technical Advisory Committee members of the EPRI Advanced
Nuclear Technology Program is acknowledged and greatly
appreciated.
This publication is a corporate

document that should be cited in the
literature in the following manner:
Program on Technology Innovation:
Tradeoffs Between Once-Through
Cooling and Closed-Cycle Cooling
for Nuclear Power Plants.
EPRI, Palo Alto, CA: 2012.
1025006.
iii
Product
Description
The Electric Power Research Institute (EPRI) has been investigating

a number of energy-related water topics that include the implications
of retrofitting existing once-through generating stations with closedcycle cooling, the cost and benefits of closed-cycle cooling, the
impacts of impingement and entrainment, alternative fish protection
technologies, water use in the electric power generation sector, and
advanced power plant cooling technologies.
Background
The electric sector is facing a number of regulatory mandates under
the Clean Air Act, the Clean Water Act, and the Resource and
Conservation Recovery Act (RCRA). One of the most challenging is
316(b) of the Clean Water Act governing fish protection at cooling
water intake structures. These regulatory actions will result in
significant costs to the electric sector and thus increases in the cost of
electricity as a result of compliance. Many fossil units are likely to
retire rather than retrofit expensive equipment to older units,
especially given current natural gas prices.
Objectives
The objective of this report is to summarize the tradeoffs between
once-through and closed-cycle cooling for existing and new nuclear
generation units.
Approach
The study drew from research conducted by EPRI, engineering and
scientific organizations, federal agencies, national laboratories, and
international organizations. The report summarizes information
from disciplines that include engineering, economics, biology, and
environmental disciplines necessary to cover the complex
considerations regarding the tradeoffs between once-through and
closed-cycle cooling systems relative to nuclear generation.
Results
Both new and existing power plants are likely to be impacted in
terms of additional operational requirements as a result of new Clean
Water Act 316(b) regulations for fish protection. For example,
EPRI estimates the cost to retrofit existing nuclear facilities with
closed-cycle cooling (in response to potential 316(b) regulations) to
be in excess of 32 billion dollars. Although cooling towers would

reduce impingement and entrainment mortality, closed-cycle cooling
results in a variety of potential site-specific environmental and social
impacts that include noise, salt drift, visible plumes, roadway icing
and fogging, safety issues, and impacts to terrestrial vegetation and
wildlife. Additionally, consumptive fresh water use from closed-cycle
cooling is estimated to be at least double that of once-through
cooling. This is at a time when fresh water is an increasingly limited
resource in many regions of the United States.
Nuclear generating units are especially limited in their ability to
retrofit new cooling towers due to space constraints, safety issues, and
cost. In particular, use of dry cooling is not feasible. This is due to
the fact that the lower steam temperatures associated with nuclear
plants result in higher efficiency penalties from the higher back
pressure associated with dry cooling. In addition, the ability to meet
safety and risk requirements for nuclear units would likely require
indirect dry cooling, which adds to the expense and efficiency penalty
of the technology. But some nuclear sites have the potential to
accommodate equally effective alternative technologies and
operational measures to protect fish and aquatic life. Requirements to
retrofit cooling towers would, in the majority of cases, reduce plant
generation as a result of heat rate and energy penalties and might
preclude new nuclear units at some existing sites as a result of the
additional space requirements necessary to accommodate closed-cycle
cooling.
Applications, Value, and Use
This report is intended to provide decision makers and other
stakeholders with technical information regarding the environmental,
financial, and operational tradeoffs among various technological
options for meeting anticipated regulatory requirements for fish and
aquatic organism protection at nuclear power plants. The report also
addresses issues such as water consumption associated with cooling
systems and opportunities to reduce water consumption.
Keywords
316(b)
Closed-cycle cooling
Cooling towers
Fish protection
Once-through cooling
vi
Abstract
This report reviews the potential tradeoffs for nuclear generating
facilities between once-through and closed-cycle cooling resulting
from three regulatory and policy drivers: Clean Water Act Section
316 (a) regulations on thermal discharges from once-through cooling
systems; Clean Water Act 316(b) regulations on entrainment and
impingement at cooling water intake structures (CWISs); and
increasing water use pressures on fresh water resources in many
regions of the U.S. The report summarizes the status of thermal
discharge requirements and 316(b) regulations, cooling water use
in power plants, water availability in the United States, and the
different kinds of closed-cycle cooling systems that are applicable to
nuclear units. This report also reviews the current population of
nuclear facilities, nationally and internationally and identifies unique
characteristics of nuclear facilities relevant to cooling water use. The
consumptive water use implications for both existing and new
nuclear facilities are examined, as well as the availability of alternative
technologies to protect fish and shellfish from impingement and
entrainment mortality at CWISs. Finally, the report discusses the
implications of retrofitting U.S. nuclear facilities with closed-cycle
cooling from the standpoint of cost, environmental considerations,
and benefits, drawing heavily from the results of the Electric Power
Research Institutes (EPRIs) research programs.
vii
Executive
Summary
Water is essential for human existence, food production, sustainable

development, and economic productivity. Water is also essential to
energy production98% of electricity generation in the United
States depends on water for cooling or as the motive force to drive
hydroelectric plants. On the basis of water withdrawal rates,
electricity generation from power plants is a major water user,
rivaling agriculture as the nations largest demand on fresh water.
However, unlike agriculture, most of the water withdrawn from
source bodies of water is returned (not consumed), typically at 1020
degrees warmer than when originally withdrawn. On the basis of
water consumption rates, electricity generation uses about 3.3% of
the U.S. fresh water resources. Supplies of fresh water are constant
and largely unexpandable. Demand for fresh water by sectors of the
U.S. economy has been increasing for decades. Competition for
limited water resources in many parts of the United States is
predicted to increase.
Most large electric power plantsincluding both fossil-fired and
nuclear plantsemploy one of two types of cooling system designs:
(1) once-through cooling, which withdraws water to extract waste
heat from the plant and returns it to (usually) the same body of
water, where the heat is dissipated; and (2) closed-cycle cooling, in
which heat is rejected to the atmosphere by evaporation of cooling
water. Use of closed-cycle cooling dramatically reduces the amount
of water that is withdrawn from the source body of water (that is, by
up to 90% compared to once-through cooling). The water consumed
in this process is a result of evaporation and blow-down of
accumulated solids and salts. Most references estimate that closedcycle cooling consumes more than twice as much water as is
consumed by evaporation from a thermal plume in the source body
of water from once-through cooling system operations.
Approximately 40% of U.S. nuclear plants use closed-cycle cooling
with the others using once-through cooling.
If plant efficiency and economics were the only consideration, then
once-through cooling would dominate and would continue to be a
preferred option for new and existing generating units. However,
since the 1980s, most new plants have been designed with closedcycle cooling. Three regulatory and/or policy drivers have affected
this development:
ix
1. Concern for potential impacts of the heated water discharged

back to the source body of water
2. Impacts of the plants cooling water intake structures on fish and
aquatic organisms
3. Fresh water availability, especially in arid regions of the United
States or regions without large bodies of water from which to
withdraw cooling water
The Clean Water Act regulates the first two of these drivers and has
been a major factor in the shift toward closed-cycle cooling over the
last two or three decades. In contrast, no federal regulations serve as a
driver to manage the consumptive use of water. As a result, state,
regional, and commercial interests are the largest drivers in this area.
As discussed in this report, managing the energy-water nexus is
becoming increasingly important, and efforts to coordinate among
federal and state authorities on water management are often
fragmented.
The purpose of this report is to examine all three of these drivers in
an integrated and holistic manner, with significant emphasis on the
second and third drivers. This report addresses:
Once-through cooling and closed-cycle cooling technology

options. Choices of preferred technologies are highly site
specific, which has led to a wide range of technical alternatives,
including cooling towers (mechanical and hyperbolic), cooling
ponds, cooling impoundments, dry cooling technologies, and
hybrid cooling systems that use both wet and dry cooling, as well
as a wide range of environmental technologies to minimize
impacts on aquatic life.
U.S. and international nuclear plant data on cooling system

design choices.
Tradeoffs that should be considered in evaluating cooling system

design choices, focused on the advantages and disadvantages of
once-through and closed-cycle cooling.
Extensive research by the Electric Power Research Institute

(EPRI) to evaluate the costs, benefits, and environmental
impacts of these choices, with a focus on the impacts of a
potential mandate to retrofit closed-cycle cooling on currently
operating fossil and nuclear facilities.
Water consumption data relative to closed-cycle versus oncethrough design choices for both current and future plants. This
report attempts to quantify, based on best data available, the
impacts of widespread expansion of closed-cycle cooling on the

consumptive use of water.
Estimated environmental impacts of once-through cooling on

source bodies of water. Clean Water Act regulations are focused
on preventing adverse environmental impacts on aquatic life as
observed at the cooling water intake structure and discharge.
EPRI research, including extensive literature searches of peerreviewed and other independent studies, has focused on
estimating localized impacts (impingement and entrainment at
the intake structure and thermal discharge) and any measurable
and sustained adverse impact on aquatic life in the source body of
water.
Key findings and conclusions from this study include:
Currently operating U.S. nuclear plants rely heavily on oncethrough cooling. A requirement to retrofit the 60% of nuclear
units that currently use once-through cooling with closed-cycle
cooling would be extremely expensive and result in extended
outages. (EPRI estimates an average of six months outage time
for the 39 once-through cooled sites and up to a year and a half
for some sites.) Retrofitting would result in a variety of potential
environmental and social impacts with relatively small
comparative benefits to the affected bodies of water. There are
many cost and biologically effective alternative technologies to
closed-cycle cooling for sites where aquatic life protection is an
issue. EPRI estimated that retrofitting all existing once-throughcooled nuclear plants would cost the nation over $32 billion (net
present value). The cost would extend to approximately $100
billion when fossil plant retrofits are included. The annualized
cost of mandating these retrofits was estimated to be almost 800
times greater than the monetized commercial and recreational
fishery benefit.
Due to a variety of factors discussed in this report, dry cooling is

not considered practical for nuclear power plants. Indirect dry
cooling has been proposed for only one new nuclear power plant,
as part of a hybrid cooling system. EPRI is considering a research
program that would investigate the design, safety, and regulatory
hurdles that would have to be overcome to use dry cooling more
broadly in nuclear power generation.
The United States relies much more on fresh water for nuclear
plant cooling and less on saline bodies of water (that is, oceans,
estuaries, and tidal rivers [O/E/TRs]) than other nations, by
more than a factor of two. The United States relies much more
on closed-cycle cooling and much less on once-through cooling
for its nuclear plants than other nations, by a factor of about 1.7.
xi
The United States is anticipated to rely extensively on existing

nuclear plant sites as the location for additional nuclear reactor
capacity. Roughly 60%80% of future nuclear capacity is
anticipated to be constructed on existing nuclear plant sites,
based on current trends. The proposed 316(b) regulation would
likely limit this option for siting new units at many existing
nuclear sites as a result of space constraints and/or permitting
issues for cooling towers.
Based on an EPRI study of fresh water withdrawals, existing

water resources, and future demands, it is clear that water supply
considerations will be an increasingly important factor for future
power generation. Increased focus on efficiency of water use and
conservation is needed to meet future water needs and the
growing demand for energy simultaneously.
Based on the best data available, closed-cycle cooling

technologies are estimated to consume at least twice as much
water as once-through cooling technologies. This finding is
based on research by the National Renewable Energy Laboratory
(NREL) using the most recent data. NREL notes that these data
contain gaps and methodological inconsistencies. More research
is needed on this issue.
The proposed 316(b) rule for existing facilities developed by

the Environmental Protection Agency (EPA) evaluated a wide
range of societal impacts that would result from mandating
closed-cycle cooling in existing U.S. electric plants, including
impacts on grid reliability, plant closures, and capacity losses.
However, the EPA did not evaluate the impacts on consumptive
water use and the resulting impacts on the competing water
demands from different stakeholders.
Recent research by the National Energy Technology Laboratory

(NETL) evaluated the increased consumptive use of water under
five different scenarios related to the conversions of power plants
to closed-cycle cooling. Based on this research, the regional
variations are expected to be significant.
EPRI research has examined the estimated impacts of oncethrough cooling on source bodies of water. The results of a July
2011 report, Do Power Plant Impingement and Entrainment Cause
Adverse Changes in Fish Populations? A Review of the Scientific
Evidence (EPRI report 1023094), are summarized in this report.
The EPRI study relied on peer-reviewed reports, blue ribbon
commission reports, and other highly credible independent
studies that focused on potential impacts on the source body of
water, that is, overall or large-scale impacts beyond the
immediate vicinity of the plant. EPRI found that
xii
virtually all of these independent studies identified little or no

evidence of environmental impacts on the aquatic populations in
the source bodies of water associated with power plant cooling
operations.
Nevertheless, EPRI has examined a wide range of commercially

available fish protection technologies for minimizing the
potential for adverse environmental impacts. Although their
performance is highly site- and species-specific, many of these
technologies have demonstrated highly effective performance
results, especially in minimizing impingement mortality. Many
of these technologies were not developed and demonstrated two
or three decades ago when closed-cycle cooling was commonly
used for Clean Water Act compliance at new facilities.
There are opportunities for balancing the associated tradeoffs

between the use of once-through cooling and closed-cycle
cooling for new plants, especially where fresh water resources are
limited. These situations could include:
New plants where consumptive use of water is a priority

consideration (for example, the upper Great Lakes).
New plants in O/E/TR regions. This is a more difficult

situation for the possible use of once-through cooling
because these O/E/TR regions may have more stressed
fisheries and because consumptive use of fresh water is not
an issue in these regions. However, new plant siting in these
regions may have an indirect impact on the consumptive use
of water if it eliminates the construction of other generation
sources using fresh water.
New plants that utilize cooling ponds or small reservoirs for

heat dissipation (cooling ponds consume less water than
cooling towers).
As cooling water resources become more constrained and as available

land for power plant siting becomes more limited in the decades
ahead, siting of new generation capacity will become increasingly
challenging. This will place increased emphasis on the optimum
utilization of existing generation sites, with their established
transmission access, water access, and infrastructure for fuel storage
and handling among other factors.
There are many examples where alternative technologies have been
used to provide for once-through cooling in lieu of cooling towers
where consumptive use of water is a concern. Alternative or nontraditional water resources will also play larger roles in the future.
xiii
Table of Contents
Section 1: Introduction ............................................1-1
Section 2: Background ............................................2-1
2.1 How Power Plants Use Cooling Water.......................... 2-1
2.2 Basic Definitions ........................................................ 2-2
2.3 Types of Closed-cycle Cooling Systems ......................... 2-4
2.3.1 Wet Cooling Towers - Mechanical Draft ............... 2-4
2.3.2 Wet Cooling Towers - Natural-Draft ..................... 2-6
2.3.3 Helper Towers ................................................... 2-7
2.3.4 Dry Cooling Towers ........................................... 2-7
2.3.5 Hybrid Wet/Dry Cooling Towers ...................... 2-11
2.3.6 Cooling Ponds................................................. 2-13
2.4 Dry Cooling for Nuclear Power Plants ........................ 2-14
2.5 Hybrid Cooling for Nuclear Power Plants.................... 2-17
2.6 Overview of the Clean Water Act Relative to Oncethrough Cooling ............................................................. 2-19
2.6.1 Thermal Discharges.......................................... 2-19
2.6.2 Cooling Water Intake Structures ........................ 2-19
Section 3: Nuclear Facility Database and Specific
Considerations ........................................3-1
3.1 Application of Once-through Cooling versus Closedcycle Cooling in the U.S. .................................................. 3-1
3.1.1 Overview of U.S. Nuclear Facilities ..................... 3-1
3.1.2 Summary of Key Differences between Fossil
and Nuclear Facilities ................................................. 3-4
3.2 Application of Once-through Cooling versus Closedcycle Cooling Worldwide ................................................. 3-6
3.2.1 Summary of Nuclear Power Plant Data................. 3-6
3.2.2 Observations and Insights from International
Data.......................................................................... 3-7
3.3 Application of Once-through Cooling versus Closedcycle Cooling for New U.S. Facilities ................................. 3-8
3.3.1 Projected Growth in Nuclear Energy in the
U.S.; Implications to Cooling Water.............................. 3-8
3.3.2 Options for Cooling Water Strategies for New
Reactors on Existing Sites in the U.S. ............................. 3-9
xv
Section 4: Comparison of Closed-Cycle Cooling

Retrofits versus Once-Through Cooling .....4-1
4.1 Once-through Cooling ................................................ 4-1
4.2 Closed-cycle Cooling .................................................. 4-2
4.2.1 Closed-cycle Cooling for New Facilities ............... 4-2
4.3 Cooling System Retrofits for Existing Facilities ................ 4-6
4.3.1 Costs of Retrofits ................................................ 4-6
4.4 Environmental Considerations.................................... 4-14
4.4.1 Environmental and Social Impacts of ClosedCycle Cooling .......................................................... 4-15
Section 5: Water Consumption Rate Data for
Once-Through Cooling versus ClosedCycle Cooling ..........................................5-1
5.1 Overview of Issue ...................................................... 5-1
5.2 Relative Water Consumption Rates for OnceThrough vs. Closed-Cycle Cooling...................................... 5-4
5.2.1 NREL Study Conclusions ..................................... 5-4
5.2.2 Empirical Derivation of Once-Through Cooling
Water Consumption Rates ........................................... 5-5
5.2.3 Recognition by EPA of Cooling Towers High
Water Consumption Rates ........................................... 5-5
5.3 How Important is a Factor-of-Two Higher Water
Consumption Rate for Closed-Cycle Cooling vs. OnceThrough Cooling? ............................................................ 5-6
5.3.1 NETL Study Conclusions ..................................... 5-6
5.3.2 EPRI Study Conclusions..................................... 5-10
5.4 Discussion ............................................................... 5-12
Section 6: Impacts of Once-Through Cooling to
Fish and Aquatic Life ...............................6-1
6.1 Thermal Discharge ..................................................... 6-1
6.2 Cooling Water Intake Structures .................................. 6-1
6.2.1 Current Level of Impingement and Entrainment
at Nuclear Facilities .................................................... 6-2
6.2.2 Impacts on the Source Waterbody ....................... 6-2
6.3 Insights from NRC Environmental Reviews ..................... 6-4
6.3.1 NRCs Environmental Review Process ................... 6-4
6.3.2 NRC Review and Approval of Nuclear Plant
Cooling Water Systems: .............................................. 6-5
6.3.3 Current Status and Findings ................................ 6-7
6.3.4 Discussion......................................................... 6-8
xvi
Section 7: Use of Alternative Fish Protection

Technologies as BTA for Nuclear
Facilities ..................................................7-1
7.1 Existing Use of Fish Protection Measures at Nuclear
Facilities.......................................................................... 7-1
7.2 Alternative Fish Protection Technologies to Reduce
Impingement Mortality ...................................................... 7-4
7.2.1 Exclusion Technologies ....................................... 7-4
7.2.2 Fish Collection and Transfer Technologies ............ 7-4
7.2.3 Velocity Caps .................................................... 7-5
7.2.4 Velocity Reduction ............................................. 7-6
7.2.5 Fish Diversion Systems........................................ 7-6
7.2.6 Flow Reduction .................................................. 7-6
7.2.7 Behavioral Devices ............................................ 7-7
7.2.8 Change in Intake Location .................................. 7-7
Entrainment Mortality........................................................ 7-7
7.3.1 Exclusion Devices .............................................. 7-8
7.3.2 Fish Collection and Transfer Technologies ............ 7-8
7.3.4 Change in Intake Location .................................. 7-9
7.4 Summary of the Potential Use of Alternative Fish
Protection Technologies and Operational Measures for
Nuclear Power Plants ....................................................... 7-9
Section 8: Summary and Conclusions .......................8-1
8.1 Consumptive Use of Water ......................................... 8-2
8.2 Tying Together the Trade-offs into Three Categories ....... 8-2
8.2.1 Existing Facilities ............................................... 8-3
8.2.2 New Plants on Existing Sites ............................... 8-3
8.2.3 New Plants on New Sites ................................... 8-4
8.3 Key Conclusions ........................................................ 8-6
Section 9: References ..............................................9-1
Appendix A: U.S. Nuclear Reactor Listing, by
Unit and by USGS Water Resource
Region ................................................... A-1
Appendix B:
U.S. Nuclear Reactor Listing, by
Site and by Site Situation/Cooling
Method ...................................................B-1
Appendix C:
Summary Tabulation of Number
of NPPs in Each Situation (per App. B) ...... C-1
xvii
Appendix D: International Application of OnceThrough Cooling vs. Closed-Cycle

Cooling .................................................. D-1
Appendix E:
EPRI National Cost Estimate for
Retrofit of U.S. Power Plants with
Closed-Cycle Cooling: Technical Brief
Clean Water Act Fish Protection
Issues ..................................................... E-1
xviii
List of Figures
Figure 1-1 Estimated Fresh Water Consumption by Sector,
1995 (DOE Report to Congress, 2006) .............................. 1-4
Figure 1-2 Estimated Fresh Water Withdrawals by Sector,
2000 (DOE Report to Congress, 2006) .............................. 1-4
Figure 2-1 Once-through cooling system schematic.................... 2-2
Figure 2-2 Closed-cycle wet cooling system schematic ............... 2-3
Figure 2-3 Schematic of mechanical-draft wet cooling tower ...... 2-5
Figure 2-4 32 cell, mechanical-draft, counterflow wet
cooling tower .................................................................. 2-5
Figure 2-5 Counterflow, natural draft cooling tower................... 2-7
Figure 2-6 Air-cooled condenser at Higgins Energy Center......... 2-9
Figure 2-7 Air-cooled condenser at Mystic Power Station ........... 2-9
Figure 2-8 Schematic of integrated water-conservation tower.... 2-12
Figure 2-9 Schematic of parallel, wet/dry cooling system ........ 2-13
Figure 3-1 USGS Water Resource Regions ............................... 3-5
Figure 4-1 Dry cooling installations in the United States by
year (Ref. 6) .................................................................... 4-3
Figure 4-2 Cost performance comparisons for nuclear plants
at five representative sites of differing meteorology
(Ref. 7) ........................................................................... 4-5
Figure 4-3 Schematic of closed-cycle cooling retrofit
arrangement .................................................................... 4-6
Figure 5-1 2010 Thermoelectric Water Consumption by
EMM Region (Ref. 19) .................................................... 5-10
Figure 7-1 Critical fish swim speeds relative to water
velocity based on 536 data points for various fish
species and size ranges. (Ref. 29) ..................................... 7-6
xix
List of Tables
Table 3-1 Number of U.S. Nuclear Plant Sites, Organized
by Cooling Water Situation............................................... 3-2
Table 3-2 Summary of U.S. Nuclear Power Plant Cooling
System Types ................................................................... 3-3
Table 3-3 Number of U.S. Reactors by USGS Water
Resources Region ............................................................. 3-6
Table 3-4 International Data on Use of Once-Through
Cooling and Closed-cycle Cooling Modes in Fresh and
Saline Water ................................................................... 3-7
Table 4-1 Cost performance comparisons for alternative
cooling systems at three plant types at five representative
sites (Ref. 7) .................................................................... 4-5
Table 4-2 Summary of national retrofit costs (from [Ref. 7],
Figure 9.1) ...................................................................... 4-9
Table 5-1 Selected Regional Water Consumption Data from
NETL Report (Ref. 19) ....................................................... 5-9
xxi
Section 1: Introduction
The generation of electric power generally requires use of water, a resource that is
used for a myriad of purposes. EPRI research has been focusing on a number of
topics that are directly and/or indirectly related to water quality, fish protection
and sustainable water use that include:
Water use and conservation in the electric power generation sector
Implications of alternative forms of generation to provide power in a carbon

constrained world (i.e., EPRIs Prism program)
Advanced cooling technologies
Impacts of impingement and entrainment and the cost and benefits of

reducing them with closed-cycle cooling
Fish protection technologies, and
Costs, benefits and other impacts of retrofit of cooling towers to existing

once-through cooled generating stations.
New regulatory initiatives, including 316(b) under the Clean Water Act
(CWA), Mercury and Air Toxics Standards (MATS) under the Clean Air Act
(CAA), and Resource and Conservation Recovery Act (RCRA) Subtitle D, all
have the potential to significantly affect existing generation in the U.S.
Greenhouse gas emissions limits for new and existing units are also being
established under the Clean Air Act. Many older fossil facilities may be retired,
rather than retrofit expensive equipment to older units, especially given current
natural gas prices, resulting in the need for new generation.
New nuclear projects will have to address water availability for cooling as part of
the tradeoffs between efficiency, cost, and other impacts. This consideration is
also potentially applicable to existing nuclear generation, as two of the current
316(b) options under consideration are based on closed-cycle cooling as the
Best Technology Available (BTA).
The electric power generation industry is one of the largest water users in the
U.S., with total withdrawal approximating that by agriculture. However, in
contrast to agricultural use, most water use by electric power is nonconsumptive that is, most water used for once-through cooling is returned to
the source waterbody. Prior to the 1970s the majority of thermoelectric (or steam
electric) generating facilities used once-through cooling systems, in which
cooling water is withdrawn from a source waterbody, passed through a condenser
where turbine exhaust steam is condensed and then returned to the source
1-1
waterbody. In recent decades, most new facilities have employed closed-cycle

cooling, in which the cooling water, after passing through the condenser, is
pumped to a cooling tower where it is cooled by evaporating part of the water to
the atmosphere which cools the remaining water. This cooled water is then recirculated back to the condenser. This is essentially a closed loop system except
for water loss through evaporation and blowdown and the compensating makeup. Closed-cycle systems significantly reduce the volume of surface water
withdrawn compared to once-through cooling, typically by more than 90%, but
significantly increase water consumption, relative to once-through cooling.
Historically, there have been three primary drivers for the shift from oncethrough cooling to closed-cycle cooling that include:
1. Concern for the potential impacts of the heated water discharged back to the
source waterbody;
2.
Impacts of the cooling water intake structure as a result of impingement of

larger fish and aquatic organisms on water screens used to prevent debris and
fish from plugging the condensers and the entrainment of smaller fish and
aquatic organisms that are exposed to heat, mechanical stress and biocides as
they pass through the cooling water system; and
3. Freshwater availability, especially in arid regions of the U.S. or regions

without large waterbodies from which to withdraw cooling water.
As discussed in this report, roughly half of todays fleet of electric power plants
still use once- through cooling. More specifically, about 60% of nuclear plants
use once-through cooling and 40% use closed-cycle cooling. This ratio is
essentially reversed for fossil plants.
In recent years there have been regulatory initiatives resulting in increased use of
closed-cycle cooling for all generating facilities. These initiatives could result in
potentially significant impacts to both fossil and nuclear generating facilities. A
regulatory requirement to retrofit cooling towers would be an economic and
engineering challenge for nuclear generating facilities. This report documents the
trade-offs between once-through cooling and closed-cycle cooling applications
for thermoelectric generating plants, including important supporting data.
Sites are often selected to supply baseload electricity to population and industrial
centers in the region of those sites, even if they have less than optimum cooling
water resources. As discussed later in Chapter 2, the once-through cooling
option, if available, has significant advantages for plant efficiency, economics, and
other factors. However, if a plant is sited in a region with limited cooling water
resources (e.g., only small rivers are available in the region), then closed-cycle
cooling may be required to avoid complete diversion of the river or excessive
heating of the source waterbody. Cooling towers withdraw substantially less
water and reject most of the plants excess heat into the atmosphere, reducing the
thermal impact on the source waterbody. Thus, closed-cycle cooling is almost
always used for plants on small rivers or those using groundwater. This
preference for closed-cycle cooling in such siting applications is equally applicable
to all large baseload thermoelectric plants both nuclear and fossil-fired facilities.
1-2
Subsequently, in the 1970s and 1980s, EPA regulations governing cooling water
intake structures (CWISs) resulted in a second reason for increased use of closedcycle cooling for new facilities: to address potential CWIS impacts to fish and
aquatic life.
Shifting cooling systems from once-through cooling to closed-cycle cooling has
positive and negative impacts. Closed-cycle cooling enables a large reduction in
the volume of cooling water being withdrawn, but increases the volume of
cooling water consumed, typically by a factor of two or more. According to the
USGS, withdrawal is defined as the amount of water removed from the ground
or diverted from a water source for use, while consumption refers to the amount of
water that is evaporated, transpired, incorporated into products or crops, or
otherwise removed from the immediate water environment.
For once-through cooling, the water is pumped through the plant, where it is
used to condense the steam from the turbine, and then is returned to the original
waterbody some 10o to 20oF warmer. This process requires large volumes of
water, but consumes very little of that water, other than the incremental
evaporative loss due to the increased water temperature. Once-through cooling
evaporative loss tends to be site-specific depending on where it is discharged (i.e.,
at the surface or on the bottom of the source waterbody), whether the thermal
plume sinks or floats, and how quickly it mixes, which is highly dependent on the
waterbody type (i.e., tidal, riverine or lake/reservoir). It can also be affected by
meteorological conditions such as wind speed and air temperature. On the other
hand, closed-cycle cooling generally withdraws 90% to 98% less water, but
consumes most of the water withdrawn through evaporation and drift causing
the near complete loss of that water (90% loss).
The electric power generation industry accounts for approximately 40% of U.S.
water withdrawals, roughly the same as agriculture (see Figure 1-2). However,
actual power plant consumption is estimated to be only 3.3% of total U.S.
freshwater consumption -- much less than municipal water needs, and
significantly less than agriculture (see Figure 1-1).
The Clean Water Act (CWA), which regulates thermal impacts and CWIS
impacts, has been a large driver in the shift in thermoelectric plant cooling from
once-through cooling to closed-cycle cooling (see Section 2.4 for details on the
CWA). However, there are no equivalent Federal regulations or policies
governing the environmental issues associated with consumptive use of water. As
discussed in Chapter 5, fresh water shortages and water use conflicts are on the
rise in many parts of the U.S. and globally.
1-3
Figure 1-1
Estimated Fresh Water Consumption by Sector, 1995
(DOE Report to Congress, 2006)
U.S. Freshwater Withdrawals, 345 Bgal/day
Mining
1%
Industrial
5%
Public supply
13%
Thermoelectric
39%
Domesitc
1%
Aquaculture
1%
Livestock
1%
Irrigation
39%
Figure II-I. Estimated Freshwater Withdrawals by Sector, 2000

(Hudson et al., 2004)
Figure 1-2
Estimated Fresh Water Withdrawals by Sector, 2000
(DOE Report to Congress, 2006)
For context, EPRI nuclear members with expertise in cooling water issues were
assembled for an EPRI-DOE-INL-sponsored working group meeting in April
2010. These attendees ranked consumptive use of water as the most important
issue that EPRI and DOE R&D programs should address. Further, the group
stated that Water is the pivotal issue for new nuclear plant siting.
1-4
Chapter 2 provides background information on how water is used to generate

electricity, basic definitions for technical terms used in the report, an overview of
the Clean Water Act relative to cooling water use and an overview of alternative
fish protection technologies. Chapter 3 provides a description of the nuclear
facilities in the U.S. and worldwide. This includes information on the overall
water withdrawal and consumptive use data associated with the once-through
cooled nuclear units, differences between once-through cooling uses for nuclear
versus fossil units, and new plant considerations.
Chapter 4 provides an overview of the differences between once-through cooling
and closed-cycle cooling in terms of impacts to fish and shellfish, environmental
impacts, cost, efficiency and economic performance. Chapter 5 provides an
overview of the differences in consumptive water use between once-through
cooling and closed-cycle cooling, and provides estimates, based on best data
available, of the potential impacts of widespread expansion of closed-cycle
cooling on the consumptive use of water in the U.S. Chapter 6 provides a review
of the potential impacts of requiring U.S. once-through cooled nuclear facilities
to retrofit to closed-cycle cooling, with information provided on alternative
closed-cycle cooling technologies, cost and environmental impacts. Chapter 7
provides information on the range of fish protection alternatives, including a
summary of the currently employed technologies and mitigation measures used at
many existing once-through cooling nuclear facilities. Chapter 8 provides the
reports summary and conclusions.
1-5
Section 2: Background
This Chapter provides background to better understand the tradeoffs between
once-through and closed-cycle cooling. It provides an explanation of how nuclear
power plants use cooling water, some basic definitions for key terms and concepts
used in the report, a summary of different types of closed-cycle cooling systems
and a summary of the Clean Water Act statutory and regulatory programs
governing the use of once-through cooling.
2.1 How Power Plants Use Cooling Water
All thermal power plants (fossil and nuclear) using steam turbines to drive the
generator must condense the low pressure steam exiting the turbine to water, in
order for it to be pumped back to the boiler, reactor or steam generator at the
pressure of the steam turbine inlet. The heat released in the condensation process
must be rejected to the environment as required by the laws of thermodynamics
governing the behavior of thermal cycles. In practical terms, in the case of these
Rankine steam cycles, condensation is required because if the steam were
compressed back to turbine inlet pressure in the vapor phase, the energy to
compress it would exceed the energy extracted from the steam during its
expansion through the turbine.
The quantity of heat which must be rejected to the environment can be quite
large, amounting to 60% to 70% of the heat generated by the plant for coal and
nuclear plants. For fossil plants, a good portion of this heat is lost up the stack,
while for nuclear plants, virtually all the waste heat must be rejected through
cooling water systems. For natural gas combined cycle (NGCC) plants, thermal
efficiency can exceed 55%, so the quantity of heat that must be rejected to the
environment is much lower. In order to maintain the required turbine exhaust
pressure at typical operating levels of 1.5 to 3.5 inches Hga, the steam
condensing temperature must be held at 90F (for 1.5 inches Hga) to 120F (for
3.5 inches Hga) necessitating the availability of a cooling water at temperatures
no greater than about 70F to 100F. As water temperatures exceed the design
maximum, the plant would have to reduce steam flow to the turbine to stay
below the turbine back pressure limit (and prevent a unit trip). This has the effect
of reducing capacity and decreasing efficiency.
The amount of cooling water required depends on the type of cooling system
used and the size and design of the condensers. For once-through cooling, where
water is withdrawn from a natural source (e.g., river, lake, ocean or reservoir) and
passed through the steam condenser where it absorbs heat and then is returned to
2-1
the source, typical cooling water flow rates are 500 to 700 gallons per minute per
MW. For a 1,000 MW plant, this corresponds to 700 million to 1 billion gallons
of cooling water flow per day. If a closed-cycle wet cooling system is used, the
water cycles between the cooling tower, where heat is removed by the evaporation
of water, and the steam condenser, where heat is absorbed to condense the steam.
Typical evaporation rates for cooling towers range from 8 to 12 gallons per
minute per MW (exclusive of blowdown), or 12 to 18 million gallons per day for
a 1,000 MW plant.
2.2 Basic Definitions
Once-through Cooling - Once-through cooling is the process whereby a steam
generating facility withdraws cooling water from a source waterbody (ocean,
river, lake or estuary), passes it through the cooling system, and returns it to the
source waterbody. The cooling water is typically drawn through a bar rack and/or
screen to remove debris and/or aquatic organisms, and pumped by the circulating
water pump through the tubes of a steam condenser. The steam from the turbine
exhaust is condensed on the outside surface of the condenser tubes, and the
condensate is returned to the boiler, steam generator or reactor to generate steam
for the turbine. The condenser cooling water is discharged back to the source
waterbody at a typical 10o-20oF differential temperature. A typical once-through
cooling system is shown schematically in Figure 2-1.
Figure 2-1
Once-through cooling system schematic
Closed-cycle Cooling - Closed-cycle (or recirculating) wet cooling systems are

similar to once-through cooling in that the steam is condensed in a water-cooled,
shell-and-tube steam condenser, but differ in that the heated cooling water is not
returned to the environment but is conveyed to a cooling component, typically a
wet cooling tower where it is evaporatively cooled and then recirculated to the
condenser. A typical closed-cycle wet cooling system is shown schematically in
Figure 2-2.
2-2
Figure 2-2
Closed-cycle wet cooling system schematic
Blowdown As water is evaporated in the cooling tower, salts and solids (Total
Dissolved Solids TDS, and Total Suspended Solids, TSS) in the cooling water
increase in concentration. To prevent scaling, fouling and corrosion in the
closed-cycle cooling system and to meet water quality standards at the point of
final cooling water discharge, water must be periodically discharged from the
closed-cycle cooling system (i.e., blowdown) and new cooling water make-up
withdrawn from the source waterbody to replace evaporative water loss, drift and
blowdown.
Drift During cooling tower operation, a percentage of the circulating water
flow will be expelled along with the heated air plume, in the form of small water
droplets, or drift. Cooling towers typically have mist eliminators to capture most
of the droplets before discharge, and the drift rate (loss of water droplets in the
cooling tower plume) is typically less than 0.0005% of the circulating water rate.
Cooling Water Intake Structure The cooling water intake structure begins at
the point of initial construction for cooling water conveyance to the condensers
and ends at the point of discharge from the cooling water pumps. The point of
initial construction may be the entrance to an offshore pipe, an intake canal,
constructed embayment or the bar racks used to prevent large debris from
damaging the passive or traveling water screens.
Impingement The process whereby fish or shellfish are caught on cooling water
intake structure screens used to prevent debris or fish from blocking or plugging
cooling water condenser tubes. Most U.S. power plants have 3/8-inch square
mesh screens but some have rectangular shaped or larger or smaller screen mesh
sizes.
Entrainment The passage of smaller fish, shellfish or other aquatic organisms
through the screens, cooling water pump, condensers and associated piping and
then discharged back to the receiving water. In this process aquatic organisms are
exposed to mechanical stresses and pressure changes of the pumps and piping, to
2-3
biocides if they pass through the system during intermittent chlorination (or
other biocides used), and to temperature differentials in the condenser tubes.
A more comprehensive list of definitions can be found at 125.92 of the 316(b)
Proposed Rule.1
2.3 Types of Closed-cycle Cooling Systems
Currently, there are a variety of closed-cycle cooling systems available for use.
These systems vary in terms of their cost, efficiency, space and water use
requirements, as well as their compatibility for use with nuclear facilities. A brief
review of these alternatives follows.
2.3.1 Wet Cooling Towers - Mechanical Draft
Wet cooling is achieved by evaporating a small fraction (typically 1 to 2%) of the
water circulated through the tower in order to cool the remaining 98 to 99% of
the water.2 Mechanical draft towers use fans to bring atmospheric air into contact
with the water to achieve the evaporation. Figure 2-3 shows a schematic of a
single cell of a typical counter-flow mechanical-draft, wet cooling tower. Figure
2-4 shows a photograph of an installed tower consisting of 32 cells. The tower
can be configured in a variety of ways. Most are rectangular, made up of a
number of individual cells (square or rectangular in shape), each cell with its own
fan. The cells can be arranged in either an in-line or a back-to-back
configuration. Finally, some round designs exist and can be either induced-draft
(where the fans are at the top of the tower and draw air up through the cells) or
forced draft (where the fans are on the side of the tower and push air through the
cells).
Federal Register, Vol. 76, No. 76, April 20, 2011, pg. 22281.
These values apply to situations where the cooling water source is fresh water and the cycles of
concentration can therefore be higher. In high salinity situations, where more frequent blowdown is
needed to reduce accumulations of solids, the cycles of concentration are lower, and more makeup
water is required. Note that fewer cycles of concentration in turn require more blowdown (and
hence more withdrawal), but not more evaporation (and hence not more consumption).
2
2-4
Figure 2-3
Schematic of mechanical-draft wet cooling tower
Figure 2-4
32 cell, mechanical-draft, counterflow wet cooling tower
2-5
The system operates by pumping water from the condenser to the top of the
tower onto a hot water distribution deck on spray headers. The water then flows
down through nozzles in the deck or header, which breaks it up into droplets and
distributes the droplets uniformly onto the fill. The water flows through the fill
in thin films or droplets depending on the type of fill, creating a large interfacial
surface for contact with the air. Fresh air is drawn (upward for counter-flow fills,
across for cross-flow fills) through the fill and into intimate contact with the
falling water. The cooling is accomplished by the evaporation of a small fraction
(approximately 1 to 2%) of the water. The cooled water then falls into a cold
water collection basin beneath the fill from which it is recirculated back to the
condenser inlet.
Some portion of the circulating water flow is discharged as blowdown from the
system back to the environment in order to control the build-up of total
suspended and total dissolved solids (TSS and TDS) brought into the cooling
system with the make-up water and air. Some of the circulating water is
entrained as small droplets by the air stream in the fill. Most of these are
removed by drift eliminators placed downstream of the fill. The few droplets
leaving the tower are referred to as drift and are currently controlled to about
0.0005% of the circulating water flow with modern, high efficiency drift
eliminators. Drift rates from older, existing installations are more typically in the
0.001% to 0.002% range.
Make-up water must be withdrawn from the water source and added to the
recirculating water loop to replace the water lost as evaporation, blowdown and
drift. The additional make-up required to replace blowdown is a strong function
of the make-up water quality, which sets the amount of blowdown required to
maintain acceptable levels of dissolved solids for control of scaling, fouling and
corrosion. The total make-up water required is a small fraction (typically 2% to
10%) of the water that would be withdrawn from a waterbody for once-through
cooling.
2.3.2 Wet Cooling Towers - Natural-Draft
Wet natural-draft cooling towers operate on a similar principle to mechanicaldraft towers, except that the natural buoyancy effect of heated air, rather than
fans, is used to draw air into contact with water. They are designed as a single
large hyperbolic shaped tower as shown in figure 2-5.
The tower is open at the top and at the base. This design creates a natural draft
as the hot circulating water heats the air, increasing the buoyancy, and causing it
to flow out the top of the tower while cooler ambient air is drawn in at the base
of the tower. As a result, these towers avoid the need for extra electric power to
operate the fans used to induce air flow in mechanical draft towers. The capital
cost to construct the large hyperbolic tower is greater than the cost of mechanical
draft towers. However, the operating cost is reduced and generation output is
increased compared to mechanical draft towers, since there are no fans. The
economic trade-off often makes natural-draft towers a preferred choice for large,
baseloaded plants. For this reason they were frequently used on nuclear plants.
2-6
From an environmental standpoint the greater height of the tower helps to

reduce issues associated with icing, fogging and particulate deposition but
increases potential aesthetic impacts.
Figure 2-5
Counterflow, natural draft cooling tower
2.3.3 Helper Towers

Some plants have added cooling towers to an existing once-through cooled
system without converting to a closed-cycle system. This modification is typically
used during hot summer months to help reduce cooling water temperatures to
below permit limits before discharge back to the source waterbody. Adding
helper towers for this purpose typically does not modify the once-through
intake system, including the CWIS and inclusive screen systems. The oncethrough cooling flow rates remain unchanged. The only difference is that heated
water flowing out of the condenser is pre-cooled by towers before discharge to
the source waterbody. Six nuclear plant sites use helper towers in the summer. All
but one of these uses mechanical-draft helper towers; one uses hyperbolic helper
towers.
2.3.4 Dry Cooling Towers
Dry cooling systems reject the heat of condensation directly to the atmosphere
with no consumptive use of water in much the same manner by which an
automobile radiator cools the hot water from the car engine. Systems for power
plant applications are of two types, called direct dry cooling and indirect dry
cooling.
2-7
2.3.4.1 Direct dry cooling

In direct dry cooling systems, low quality steam is routed from the turbine
exhaust directly to air-cooled condensers (ACCs) through a series of ducts and
risers. The ACC consists of a number of cells. Each cell is of an A-frame
construction with bundles of finned tubes sloping down from a steam duct at the
top to a condensate collection line at the bottom. In the bottom of each cell is a
large, axial flow fan which draws air from the surrounding atmosphere and forces
it across the tube bundles to absorb the heat from the condensing steam. The
individual cells are arranged in rows (streets) along a common steam duct;
typically with several streets, each with its own steam duct, arranged in parallel.
The ACC is sized to maintain a certain steam condensing temperature and
corresponding turbine exhaust pressure for a given total steam flow at a given
ambient air temperature. Typically sized ACCs have an initial temperature
difference (ITD), defined as the steam condensing temperature minus the
ambient air temperature, of around 40F. Therefore, in hot arid regions where
the ambient temperature can reach 110F or higher this corresponds to a
condensing temperature of 150F and a corresponding turbine exhaust pressure
of around 7.5 inches Hga.
When compared to a typical design point with wet cooling systems discussed in
the previous paragraph, plant performance will be lower with dry cooling as a
result of the higher backpressure. Because of the higher back pressure, a different
turbine design capable of operating well above traditional exhaust pressures is
required. Furthermore, for plants of equal capacity an ACC will:
have a larger footprint than the comparable wet cooling tower
be significantly more expensive than the comparable wet cooling system

including both the cooling tower and the surface condenser
consume more operating power for the ACC fans than do the pumps and
fans for a wet cooling system.
Many of these installations are on fossil plants in hot, arid sites, as seen in Figure
2-6, where sufficient cooling water to support wet cooling was simply not
available; others have been installed at fossil sites near large water bodies, as
shown in Figure 2-7. Such installations were motivated by a variety of reasons
including avoiding the environmental effects of aqueous discharge or
impingement/entrainment on the source waterbody or the elimination of cooling
tower plumes and drift and potential icing particularly in the vicinity of airports,
highways or densely populated urban areas. These applications are designed for
the higher condenser backpressure and reduced efficiencies associated with dry
cooling.
2-8
Figure 2-6
Air-cooled condenser at Higgins Energy Center
Figure 2-7
Air-cooled condenser at Mystic Power Station
2.3.4.2 Indirect dry cooling

Indirect dry cooling systems typically consist of a conventional shell-and-tube
surface condenser and an air-cooled heat exchanger (ACHE) (not a condenser)
2-9
in which the hot cooling water from the surface condenser is cooled (not
condensed) in finned tubes, over which ambient cooling air is blown by large
fans. In concept, the indirect dry system is similar to the closed-cycle wet cooling
system where the wet cooling tower is replaced with the ACHE. In this case no
water is consumed in the process, and no water is withdrawn from, or blown
down to, the environment.
Indirect dry cooling is more costly (with the addition of a surface condenser and
circulating water pumps), and has a greater adverse effect on plant performance
than direct dry cooling. This is a result of the terminal temperature difference of
the surface condenser, the circulating water pumping power requirement through
the ACHE, and lower temperature differential on the ACHE. Currently, no
plant in the US uses indirect dry cooling for the full cooling capacity. A single
fossil plant installation from the 1970s (San Juan Generating Station Unit 3) was
designed to provide significant water conservation with a large air-cooled section
mounted above the wet cells. However, the tube bundles have been severely
damaged by condensate freezing, and to date, this approach has not been used
elsewhere. A number of wet cooling towers have a small dry heat exchanger at
the top of the tower for purposes of plume abatement, but they provide little (~
5%) reduction in water withdrawal or consumption compared to conventional
wet cooling towers.
2.3.4.3 Dry cooling--retrofit considerations
All dry cooling systems to date have been installed on new plants which were
specifically designed to accommodate the operating constraints imposed by dry
cooling, such as using turbines which can operate at elevated exhaust pressures in
the range of 8 to 10 inches Hga. Retrofitting existing plants from once-through
cooling or even closed-cycle wet cooling to dry cooling would introduce
significant difficulties. Existing turbines are normally limited to operation at
exhaust pressures in the range of 4 to 5 inches Hga. At some hot sites, dry
cooling would be unable to achieve these condensing pressures at any reasonable
size and cost, thus requiring either changing out the turbine as part of the retrofit
or incurring significant load reductions on the hot days when energy demand is
generally the greatest. Even at cooler sites where allowable backpressures could
be maintained for most of the year, the ability to duct turbine steam from inside
the existing turbine hall to the ACC located outside is often extremely difficult
and costly. In addition, since the steam ducts must be kept relatively short to
minimize steam duct pressure drop, the ACC must be located close to the plant
building. The large height and footprint of an ACC can make it impossible to
find an acceptable area in which to place the equipment.
In recognition of these issues, EPA rejected the option to require dry cooling
from consideration in the current rulemaking for existing plants. (See Section 2.6
for discussion of rulemaking.)
2-10
2.3.5 Hybrid Wet/Dry Cooling Towers

The term hybrid cooling refers generically to a cooling system with both wet
and dry cooling elements. Either or both are available for handling the plant heat
load as conditions dictate. The wet and dry elements can be integrated in a single
structure or arranged as separate structures operating in series or parallel. Also,
hybrid systems can be designed with the objective of either plume abatement or
water conservation. The towers in which the dry and wet elements are integrated
in a single tower structure have typically been designed for plume abatement
although a few have been built with significant water-conserving capability.
2.3.5.1 Integrated hybrid towerplume abatement
Plume abatement towers are essentially all-wet systems that employ an air-cooled
heat exchanger in series with the wet tower. While the dry section rejects some
portion of the heat load and, therefore, provides some amount of water
conservation, it is typically less than 5%. The primary function of the dry section
is to provide a flow of heated dry air which can be mixed with the saturated
exhaust plume from the wet portion of the system. This results in a tower exhaust
plume in which the psychometric conditions are above the point of saturation
during those cold, high-humidity periods of daytime operation when the plume
from an all-wet cooling tower is likely to be visible. These towers can also be used
to reduce fogging or icing of nearby runways or roadways.
2.3.5.2 Integrated hybrid tower---water conservation
The only example of an operating integrated hybrid tower providing significant
water conservation exists on Unit 3 of the San Juan Generating Station, a fossil
plant in San Juan, New Mexico. It consists of a conventional shell-and-tube
steam condenser coupled to a hybrid tower with an air-cooled dry section on top
which discharges into a wet cooling tower beneath and was designed to use only
30% of the water required for all-wet cooling. A schematic of the system is
shown in Figure 2-8.
As noted previously, this design has not been replicated in the U.S., although a
few units using a similar approach have used in other countries. Hybrid cooling
for water conservation in the U.S. has predominantly been implemented with a
parallel system with separate wet and dry elements.
2-11
Figure 2-8
Schematic of integrated water-conservation tower
2.3.5.3 Hybrid (parallel wet/dry) cooling

The more common approach to hybrid cooling is the so-called parallel wet/dry
system consisting of separate cooling circuits---one dry and one wet---operating
in parallel. The arrangement is shown schematically in Figure 2-9.
This system has the capability to split the steam flow and, hence, the cooling load
between the dry element, consisting of an ACC, and the wet element, consisting
of a surface condenser coupled with a wet cooling tower. The system is selfbalancing and the division of the heat load between the wet and the dry elements
is determined by ambient conditions. When the ambient temperature drops low
enough so that the full heat load can be handled by the ACC at an acceptable
turbine exhaust pressure, the wet system can be shut off. The annual water
requirement is determined by the relative design capacity of the wet and dry
elements, meteorological conditions, and operational goals. Typical design points
result in annual water use of between 20% and 80% of that required for an all-wet
system.
2-12
Figure 2-9
Schematic of parallel, wet/dry cooling system
Hybrid cooling can overcome some of the drawbacks of all-dry cooling, such as
the hot day performance penalty on plant output while still achieving significant
water savings. The wet element can be sized to minimize or even eliminate the
problem of elevated turbine exhaust pressure on the hottest day. However, the
cost is still significantly higher than wet cooling and may approach that of all-dry
cooling, depending on the annual water availability.
Retrofit considerations, other than the turbine exhaust pressure issue, are similar
to those for all-dry cooling with regard to the difficulties of ducting the steam to
the ACC and in finding a satisfactory place to locate the ACC close to the
turbine building.
2.3.6 Cooling Ponds
Cooling ponds are constructed ponds large enough to provide condenser cooling
water without the need for a cooling tower. Such ponds are most common in
more arid parts of the country. Once the pond is constructed it is normally filled
from a nearby river during periods when there is adequate stream flow. The same
source is typically used to replenish the evaporative loss or drainage into the soil.
As discussed in the next chapter, over 15% of U.S. reactors use cooling ponds.
Cooling ponds require a significant amount of land, and are not feasible in many
topographical situations or in areas where groundwater could be affected.
Although typically more expensive up-front (constructing a man-made pond or
lake is typically more expensive than erecting cooling towers), the cooling pond
has the advantage of transferring a larger percentage of waste heat to the
atmosphere via convection, radiative heat transfer, and lower evaporation rates
due to lower differential temperatures relative to cooling towers, thereby reducing
the rate of evaporation and thus reducing the rate of consumptive water loss. In
2-13
contrast, virtually all of the heat transfer from a cooling tower occurs by rapid
evaporation (with its associated higher moisture content and higher rate of water
loss). Cooling pond systems maintain the large flow rates associated with oncethrough cooling, but because these cooling ponds are dedicated to plant cooling,
their environmental impacts are typically much less. Some nuclear plants are sited
on cooling ponds that are man-made, and not considered waters of the U.S. As
such, they are considered water treatment ponds and therefore are exempt from
aquatic life and thermal discharge regulations. These plants are identified in
Chapter 3 as Situation 1B and are listed in Appendix B. Additionally, as a
result of post 9-11 security requirements, access restrictions for fishing on cooling
ponds have increased.
2.4 Dry Cooling for Nuclear Power Plants
To date, dry cooling has not been considered a viable option for nuclear power
plants. There have been only two dry cooled nuclear plants built anywhere in the
world, and none in the U.S. One of these was a small (~100MWe) nuclear plant
at Schmehausen, Germany using an indirect dry system with an innovative
natural-draft tower design. The plant no longer operates. The second is a very
small four-unit plant at Bilibino in northern Siberia, built in the 1970s. The four
small units, only 12 MWe each, provide district heating plus some electrical
power to the area. Dry cooling was selected because the plant is located in
permafrost where flowing water is problematic. The plant design is unlicensable
in the U.S. and is scheduled for decommissioning later this decade.
There are six impacts that make it difficult to use dry cooling on modern, fullscale nuclear units:
1. Efficiency: Dry cooling systems are extremely inefficient in comparison to
water cooling. Three factors contribute to this:
-
Turbine output loss with increasing exhaust pressure: Steam turbines

suffer a loss in output at constant steam flow if the operating exhaust
pressure exceeds the design exhaust pressure. Dry cooling systems usually
have a higher steam condensing temperature (and corresponding higher
turbine exhaust pressure) for the same steam flow and a slightly higher
cooling system heat load at the same ambient conditions.
Dry cooling with an air-cooled condenser is typically sized to produce a
condensing temperature that is 35F to 45F above the ambient dry bulb
temperature. Closed-cycle cooling systems are systems are limited by the
ambient wet bulb temperature. For a closed-cycle system with a
mechanical-draft, wet cooling tower, the condensing temperature would
be expected to be 30F to 40F above the ambient wet bulb temperature
during the hottest periods, rising to 50F to 60F above wet bulb during
the colder periods of the year.
At any relative humidity below 100%, the wet bulb temperature is less
than the dry bulb temperature. Depending on the climate at the site, the
average difference between the dry bulb and wet bulb during the summer
2-14
months can range from 10F to 20F and the maximum difference at the
hottest hours can exceed 50F. Therefore differences in turbine exhaust
pressure can range from 2 to 5 inches Hga at design conditions.
Depending on the turbine type and design, this can represent a 5 to 10%
reduction in gross output. On average, over the course of a year the
difference is less, typically ranging from 1 to 2%. Turbine output loss
would be even greater when compared to the more efficient oncethrough cooling system option.
-
Required reduction in steam flow to protect the turbine: The operation

of any steam turbine is limited to a design maximum exhaust pressure to
avoid damage to the last stages of blading. Turbines are normally
equipped with a warning system which alarms at some backpressure and
then trips at some higher backpressure. Typical values for turbines
selected for units intended to be equipped with once-through or closedcycle wet cooling would have a design backpressure of 1.5 inches Hga
(for most once-through systems) to 2.5 inches Hga (more typical for
closed-cycle wet systems). Both would typically have an alarm point
around 4 inches Hga and a trip point of about 5 inches Hga. If the unit
is intended to be equipped with dry cooling, the likely turbine selection
would be an extended backpressure turbine with a design point of
around 2 to 3 inches Hga but an alarm of 7 to 7.5 inches Hga and a trip
point of 8 inches Hga. Some recent installations have turbines that can
operate at 9 to 10 inches Hga. If the operating point approaches the
alarm point, it is normal procedure to reduce the steam flow to the
turbine to reduce the exhaust pressure to a more comfortable level.
Depending on the reduction required this can reduce the turbine output
proportionally and can amount to perhaps a 15% to 30% reduction in
turbine gross output for a short time.
Higher operating power requirements with dry cooling: The operating
power requirements for a dry cooling system (fans on the air-cooled
condenser) are typically higher than the operating power requirements
for a wet cooling system (cooling tower fans and circulating water
pumps) for the same steam flow and cooling system heat load and
ambient conditions. This additional operating power reduces the net
output of the unit. The magnitude of this difference varies with system
design and site characteristics but can be 0.5% to 1.5% of plant output
for a closed-cycle cooled plant. This difference is even larger when
compared to a once-through cooled plant, in the 3% to 6% range.
The higher efficiency penalties occur on the hottest days of the year,
when electricity demand is the highest, power prices are the highest, and
when replacement power may not be readily available. [Ref. 1]
2. Turbine design: Nuclear plant turbines suffer more from increased

backpressure than do fossil turbines. First, the nuclear steam cycle operates at
high pressure turbine inlet temperatures and pressures that are lower than
fossil units and, as a result, changes in exhaust conditions represent a greater
percentage change in the energy that can be extracted from a steam flow
operating between the two end points. EPRI is not aware of any
2-15
manufacturer that offers a nuclear turbine design for extended or elevated

backpressure operation, as typically required for turbines at dry cooled plants.
All existing plants designed, built and operated on either once-through or
closed-cycle wet cooling are equipped with turbines with 4 to 5 inches Hga
alarm/trip points. For even very large air-cooled condensers, these limits
would be exceeded at ambient temperatures above 100F. Therefore, at most
sites there would be a number of occasions each year where steam flow would
have to be reduced. At many sites, temperatures above 100F can occur for
hundreds of hours a year.
3. Cost: Dry cooling is cost-prohibitive as a retrofit to current plants. EPA has
acknowledged this option as impractical in both its Phase I rulemaking and
its current rulemaking. For new plants, dry cooling is always evaluated as an
option, but has been rejected consistently during the licensing process (see
expanded discussion below). Note that direct dry cooling is currently not an
option for nuclear plants (for safety and regulatory reasons), and that the
indirect dry cooling alternative is much more expensive, as discussed above,
in terms of both capital and operating costs.
4. Land use: Dry cooling requires large amounts of open land directly adjacent
to the reactor to install.3 As a retrofit on current plants, many existing sites
could not physically accommodate dry cooling.
5. Licensing and safety: Direct dry cooling, with an open, uninterrupted path
from the ACC steam duct back to the steam generating elements of the
reactor presents significant licensing challenges for nuclear safety reasons.
There are a number of transient scenarios (e.g., loss of feedwater, turbine
trip) for which all nuclear plants must be able to demonstrate ample safety
margins, for which direct dry cooling would not satisfy regulatory
requirements. Transients such as a loss of offsite power are more benign if
post trip decay heat can be dissipated to a water-cooled condenser. Dry
cooling, with its lower thermal mass, would limit the rate of this heat
removal and could lead to higher temperature or pressure transients in the
reactor as a result. Another hypothetical scenario of concern would be a leak
in ACC finned tubes, which could allow direct escape of reactor steam to the
environment under some scenarios. Reactor steam is slightly radioactive in
Boiling Water Reactors (BWRs), with most of the radiation coming from
N-16 decay with a very short half-life (seven seconds). In Pressurized Water
Reactors (PWRs), if direct dry cooling is used, a hypothetical primary to
secondary leak could release radioactivity into the secondary circuit, allowing
small amounts of radioactivity in the turbine exhaust steam. (This is not a
concern if indirect dry cooling is used.) In both BWRs and PWRs, releases
to the atmosphere via a leak in an ACC finned tube would lack the filtering
capability of a water-cooled condenser. These releases would be small, and
insignificant from a public health and safety perspective. However, they
could be significant in licensing calculations and safety analyses of
3
Calculations performed for desert regions (e.g., Arizona) indicate the energy penalty could be 30%
or greater. One plant calculated a land requirement for dry cooling at its site of the equivalent of
about ten football fields.
2-16
hypothetical accident scenarios, and might be significant enough to show up

in a probabilistic risk analysis as a negative for dry cooling. For these reasons,
it is unlikely that a large nuclear plant would rely exclusively on dry cooling.
6. Transient conditions: ACCs can suffer reliability problems caused by wind
gusts, which cause transients in the heat removal rate from the ACC. These
rapid changes in cooling capacity could be sufficient to initiate unplanned
reactivity changes or even a reactor transient. This in turn would likely
introduce new licensing issues that would require NRC review and approval.
Note that utilities with some flexibility in both new plant siting and technology
options for available sites are more likely to consider nuclear generation for sites
with adequate cooling water resources, and more likely to consider non-nuclear
technology options (e.g., NGCC) for sites with poor water resources, especially
sites requiring dry cooling. In fact, most of the dry cooled plants in recent years
have been gas-fired combined-cycle plants. For these plants, typically equipped
with relatively small steam turbines (175 to 250 MW), extended backpressure
designs are common and dry cooling can be more easily accommodated.
New plant Combined License Applications (COLAs) evaluate all options for
heat dissipation. In theory, dry cooling is relatively more feasible for new
generating plants, than as a retrofit on existing facilities because accommodations
could be designed into the plant to address some of the above issues. In the
nuclear area, some small advanced reactor concepts being developed today are
considering dry cooling as an option for selected market applications. However,
none of the planned deployments of standardized GEN III+ Advanced Light
Water Reactors (ALWRs) will use dry cooling. All new plant COLAs submitted
to NRC to date have rejected dry cooling as infeasible for the site or
uneconomical because of lost electrical generating efficiency and significantly
higher capital and operating costs. It is likely that new nuclear plant applications
for the foreseeable future will continue to favor sites that allow for sufficiently
reliable and long-term assured water resources, thereby avoiding the reliability,
efficiency and cost penalties associated with dry cooling.
For similar reasons, EPA rejected the option to require dry cooling technology in
both its Phase I rulemaking for new facilities (2001) and its current rulemaking
for existing facilities. In its proposed rule [Ref. 2], EPA states: Dry cooling is
not demonstrated and available for nuclear facilities, due to the backup cooling
systems and related safety needs required at a nuclear facility.4
2.5 Hybrid Cooling for Nuclear Power Plants
The use of hybrid cooling on nuclear plants faces the same question of the
acceptability of using ACCs as was discussed for all-dry cooling. All the hybrid
systems to date have been used on fossil plants, either coal-fired steam plants or
gas-fired, combined-cycle plants. The parallel arrangement using an ACC has
been the preferred design in all cases. For nuclear plants, hybrid systems have
4
2-17
been proposed. For example, the cooling system for Dominions planned North
Anna Unit 3 uses a series arrangement with the ACHE in service during drought
periods. The use of a hybrid tower with a wet cooling tower and ACHE can be
arranged in either series or parallel. However, the capital cost and operating
power requirements of this approach are both significantly higher than those for
a hybrid system with an ACC as the dry element.
Despite the issues discussed earlier related to total reliance on dry cooling, the use
of dry cooling to augment a cooling system that relies primarily on wet cooling is
technically feasible for a large nuclear plant. Some new nuclear plants are
considering the addition of a small amount of indirect dry cooling to enable a
plume abatement capability in a mechanical-draft cooling tower.5 The small
amount of dry cooling used to provide this function is sufficient to eliminate the
visible plume exiting the tower, and also helps reduce water consumption rates.
These plume abatement systems do not pose a safety concern.
A hybrid system with dry cooling could also be used to compensate for either
water supply limitations or discharge temperature limitations during drought
conditions or summer heat waves. For example, Dominion has analyzed drought
scenarios for its planned North Anna Unit 3, and has opted to include in the
design a closed-cycle, combination dry and wet (hybrid) cooling tower system.
This system includes a wet mechanical tower with an air-cooled dry section for
water conservation, with make-up water supplied from Lake Anna, and a
separate dry tower that can be brought on-line in specific circumstances. The
make-up water to the wet tower will replace water lost from the operation of the
wet tower, including losses from evaporation, blowdown, and drift. The hybrid
cooling tower system will have two modes of operation, Maximum Water
Conservation (MWC) and Energy Conservation (EC). In the MWC mode, a
minimum of 1/3 of the heat is rejected from the plant via dry cooling. In the EC
mode, the dry tower fans are turned off, and 100% of the heat is rejected in the
wet tower (normal closed-cycle cooling). The dry section of the (hybrid) wet
tower continues to operate to conserve water.
A variation of the hybrid tower (different than the North Anna-3 design) would
use a dry section above the wet tower section where cooler outside air is drawn in
through ducts while the warm moist air from the wet section exhaust passes over
the outside of the ducts. Water from the wet section exhaust condenses on the
cooler dry section duct surfaces and falls back into the process stream before
leaving the cooling tower, thereby reducing the water loss due to evaporation.
Nuclear power plants may also consider non-traditional water sources, if
available. This option is discussed in a later section. Advanced reactor designs
that are technically and economically more compatible with the use of dry
cooling (e.g., High Temperature Gas Reactors, or HTGRs), might be the best
option for future generations of nuclear units with water constraints.
5
Hybrid wet/dry cooling towers are sometimes designed for plume-abatement such that the
cooling towers are capable of operating without a visible plume by using a combination of dry and
wet cooling. See COL applications for North Anna-3 & Calvert Cliffs-3 for details.
2-18
2.6 Overview of the Clean Water Act Relative to Once-through

Cooling
The Clean Water Act regulates the discharge of heat into the environment, as
well as the withdrawal of cooling water into a cooling water intake structure. This
Section provides a summary discussion for each.
2.6.1 Thermal Discharges
Heat is regulated as a pollutant under the Clean Water Act (CWA) and water
quality criteria have been established to limit the discharge of waste heat.
Regulations governing waste heat discharge by power plants are implemented as
part of the National Pollutant Discharge Elimination System (NPDES)
regulatory program administered by the EPA. In most cases administration
authority has been delegated to the states. Allowable mixing zones are generally
established based on waterbody type. Thermal plume dimensions are set to
ensure safe passage of fish and aquatic life and therefore limits are sometimes set
on the cross sectional area to allow safe fish passage. Limits may also be set on
the amount of contact with the waterbody substrate to protect benthic organisms.
Due to tidal movement in both directions, limits are often set based on a tidal
prism in estuaries.
The CWA recognizes that heat is somewhat unique as a pollutant in that it is a
physical rather than chemical change in receiving waters and causes a temporary
change in water condition. This has resulted in a unique variance provision for
thermal discharges under 316(a) of the Act. This provision allows a facility to
exceed the water quality criterion if the facility can demonstrate that the
alternate effluent limit will ensure protection of a balanced population of fish
and other aquatic life in and on the waterbody. A number of nuclear facilities rely
on a 316(a) variance; further discussion on this topic is found in Section 6.1 of
this report.
2.6.2 Cooling Water Intake Structures
Section 316(b) was included as part of the 1972 Clean Water Act amendments.
The statutory provision required that the location, design, construction and
capacity of cooling water intake structures reflect the best technology available
(BTA) for minimizing adverse environmental impact. EPA first issued
regulations to implement this statutory requirement in 1976. However, those
regulations were challenged and remanded back to EPA by the Fourth Circuit
Court in 1977 on procedural grounds. As a result of litigation in 1993, EPA
initiated work on a new rule and subsequent to a consent decree, set a schedule
for trifurcation of the rulemaking into three phases; specifically, Phase 1 would
address New Facilities; Phase II would address existing power plants above 50
million gallons per day MGD of cooling water; and Phase III would address
existing power plants not covered by Phase II and other industrial facilities.
The Phase II rule addressed existing power plants that used in excess of 50
MGD. The Phase II regulations were issued on July 9, 2004 [Ref. 3]. These
2-19
regulations were challenged by a number of environmental stakeholder

organizations and industry, and the case was heard by the Second Circuit Court.
The Court determined that use of restoration measures and the Cost-Benefit
Test could not be used as compliance options. More importantly, the Court said
that EPA based its determination that closed-cycle cooling was not BTA for
existing facilities at least in part, due to the cost of the technology relative to the
environmental benefits. The Court pointed out that consideration of the
environmental benefits was not allowed for the Phase II Rule. The Court
remanded this determination back to EPA for clarification. The Court clarified
that EPA could consider factors that included industries ability to bear the cost,
impacts to energy production and efficiency and adverse impacts associated with
retrofits in making this determination.
As a result of the Decision, the industry filed a petition for Certiorari with the
Supreme Court for review of the Decision on the use of restoration and
consideration of cost relative to benefit. The Supreme Court would not consider
the Second Circuits decision on use of restoration, but did agree to review the
issue of cost in making the BTA determination, and issued its determination on
April 1, 2009. The Supreme Court upheld EPAs authority to consider cost
relative to the benefit in making the BTA determination to the extent it wished
to do so. Based on the Second Circuit and Supreme Court Decision, EPA
withdrew the 2004 regulations and engaged in a new rulemaking, and proposed
regulations for existing facilities that were published on April 20, 2011 [Ref. 2].
The proposed rule incorporated the scope of the prior Phase II Rule plus the
Phase III Rule.
EPAs proposed rule applies to all facilities (both thermoelectric and
manufacturing) that use over 2 MGD of cooling water. The agency considered
four options for the proposed rule that are summarized as follows:
Option 1 - The preferred option established separate requirements for existing
once-through cooled facilities and new units at existing facilities. Closed-cycle
cooling was proposed as BTA for new units at existing facilities. Requirements
for new facilities are generally very similar to those in the Phase I Rule for new
facilities. For existing electric power generating units, EPA proposed BTA
separately for impingement and entrainment. Impinged organisms are defined as
those that cannot pass through a 3/8-inch mesh sieve (i.e., screen) while
entrained organisms are those that would pass through a 3/8-inch mesh sieve.
EPA proposed two alternatives for impingement compliance. In Alternative 1,
BTA for impingement is based on modified traveling screens with a fish return
for finfish. Facilities choosing this option must reduce impingement mortality by
69% monthly and 88% annually, to be verified by biological monitoring. In
Alternative 2, facilities must not exceed a through-screen velocity of 0.5 feet per
second (fps). BTA for impinged shellfish in tidal waters is based on the reduction
that can be achieved by a properly deployed and maintained barrier net. There
are additional requirements to address fish entrapment that may be an issue for
some facilities.
2-20
For entrainment, BTA is to be determined by the permitting authority on a caseby-case basis for all facilities withdrawing more than 125 MGD actual intake
flow (AIF). Such facilities are required to submit peer reviewed information on
all life stages of entrained species, the cost and performance of technologies to
reduce entrainment (including both closed-cycle cooling and alternative
entrainment reduction technologies and operational measures), environmental
impacts resulting from technologies, the benefits of technologies and any impacts
of technologies to regional electric supply. Facilities withdrawing between 2
MGD design intake flow (DIF) and 125 MGD AIF are not required to submit
the peer reviewed information but are also potentially subject to entrainment
requirements on a case-by-case basis.
Option 2 The same Option 1 requirements apply for new units at existing
facilities under Option 2. Also, the same Option 1 requirements apply for
impingement mortality reduction for all facilities withdrawing more than 2
MGD. However, flow reduction commensurate with closed-cycle cooling is
BTA for all facilities that withdraw more than 125 MGD DIF. In addition, the
entrainment reduction information requirements for Option 1 do not apply since
closed-cycle cooling is designated as BTA.
Option 3 The same Option 1 requirements apply for new units at existing
facilities as well as the Option 1 requirements for impingement mortality
reduction. However, for this option, closed-cycle cooling is designated BTA for
all facilities that withdraw more than 2 MGD.
Option 4 - The same Option 1 requirements apply for new units at existing
facilities. For impingement mortality, the uniform Option 1 requirements would
only apply to facilities that withdraw 50 MGD or more of cooling water.
Facilities using between 2 MGD and 50 MGD DIF would be subject to
impingement reduction requirements on a case-by-case basis and all facilities
withdrawing more than 2 MGD would be subject to entrainment reduction
requirements on a case-by-case basis.
In summary, closed-cycle cooling was established as BTA for new units at
existing facilities under all four options. For existing units, closed-cycle cooling
for entrainment could be required on a case-by-case basis for all facilities over 2
MGD under Options 1 and 4. For Options 2 and 3, closed-cycle cooling is BTA
for facilities using more than 125 MGD AIF and 2 MGD DIF, respectively.
Impingement mortality reduction is required under all four options but is based
on compliance using options other than closed-cycle cooling.
For nuclear plants, all of which withdraw much more than 125 MGD, these
options can be more simply summarized as follows: Option 1 (the recommended
option) proposes a one-size-fits-all national standard for impingement mortality,
along with some flexibility in addressing entrainment. Options 2 and 3 would
effectively mandate closed-cycle cooling for all nuclear facilities.
The EPA recommended option in the 2011 proposed rule for existing facilities at
existing sites allows for some flexibility in selecting the best technology available
2-21
(BTA) in the case of entrainment (requirements for impingement mortality

reduction under the recommended option are limited and could be very costly).
For entrainment, the NPDES permitting authority is required to consider nine
environmental and social factors in choosing a best technology available:
1. Number/types of organisms entrained
2. Entrainment impacts on the waterbody
3. Quantified and qualitative social benefits and social costs of available
entrainment technologies, including ecological benefits and benefits to any
threatened or endangered species
4. Thermal discharge impacts
5. Impacts on the reliability of energy delivery within the immediate area
6. Impacts on changes in particulate emissions or other pollutants associated
with entrainment technologies
7. Land availability inasmuch as it relates to the feasibility of entrainment
technology
8. Remaining useful plant life, and
9. Impacts on water consumption.6
Some of these factors may limit the use of cooling towers. For example, if
mandating cooling towers would result in an unacceptable impact on water
consumption, or if there is insufficient land available for cooling towers, or if the
particulate emissions from the cooling tower exceed regional limits under the
Clean Air Act, then the permitting authority could determine that an existing
facility would be allowed to continue using once-through cooling, as long as
other aquatic life protection features (e.g., wedge-wire screens, deep water
intakes) can serve as best technology available. If there is no alternative fish
protection technology to reduce entrainment for which the permitting authority
deems the benefit is not significantly greater than the cost, then the permitting
authority could determine that the existing cooling water intake structure is BTA
for entrainment.
However, if a new unit is added to that same existing site, the proposed rule
would likely require the new reactor to use closed-cycle cooling, even if that site
possesses identified and acknowledged disqualifying factors that make cooling
towers unacceptable for the existing facility units. Note that the 2001 CWA
Phase I rule applicable to new facilities would allow for the use of once-through
cooling for new nuclear plants at new (i.e., greenfield) sites under certain
conditions.
The Phase 1 rule allowed for expedited approval for closed-cycle cooling (Track
1) and a Track 2 or demonstration track approach that requires any
combination of design measures, technologies and operating methods to reduce
6
2-22
adverse environmental impact to a level comparable to that which would be

achieved under Track 1. The EPA defined comparable as reductions of both
impingement mortality and entrainment to 90% or greater of the Track 1
reduction. The Track 2 approach requires a Comprehensive Demonstration
Study (CDS) that must be submitted to the permitting authority along with the
NPDES application that evaluates all the options the facility intends to use.
2-23
Section 3: Nuclear Facility Database and

Specific Considerations
3.1 Application of Once-through Cooling versus Closed-cycle
Cooling in the U.S.
3.1.1 Overview of U.S. Nuclear Facilities
Currently, 104 reactors are licensed for commercial generation of electricity by
the U.S. Nuclear Regulatory Commission (NRC). These reactors operate on 65
sites in the U.S. in 31 states. Worldwide, there are about 450 reactors operating
in over 30 countries, supplying about 15% of global electricity production. 60% of
all world reactors are licensed to operate in the U.S., France, and Japan.
Regarding cooling system design details and siting situations in the U.S., the
following groupings were identified in Cooling Water Issues and Opportunities
at U.S. Nuclear Power Plants (Dec. 2010, Ref. 4), and are repeated here in this
report, with data updates as necessary.
Key summary data are provided below. They are based on details in Attachments
A, B, and C, which are spreadsheets that provide the following nuclear plant data
for the United States:
Attachment A: Listing of all currently operating reactors (104) and planned

reactors with Combined Operating License Applications (COLAs) or Early
Site Permits (ESPs) on file with NRC, organized by U.S. Geological Survey
(USGS) water resource regions, along with other relevant data
(operator/licensee, State, cooling water source basics, cooling system basics,
condenser flow rate, reactor type/NSSS supplier, summer capacity, thermal
output, and operating license issuance date). In addition to the 20 COLAs
that are under active NRC review, Attachment A also lists other new plants
with only announced plans for future submittals, prior submittals with NRC
review currently suspended, and Watts Bar Unit 2 construction completion.
See Figure 3-1 and Table 3-3 at end of this section for details on USGS
resource regions.
Attachment B: Breakdown of the existing 65 U.S. nuclear power plant sites,

organized by cooling water situation. Additional site information in this
table includes, for example, cooling water source description, site size (acres),
intake structure location and design, and discharge structure location and
3-1
design. New plant data are also displayed, including initial data on four
greenfield sites, which add to the 65 existing sites.
Attachment C: Summary tabulation of the number of NPPs in each cooling

water situation, organized by the groupings in Attachment B, on both an
individual reactor basis and a plant site basis. Data are also broken down by
current plants and new plants in these categories.
The summary table below lists the number of plant sites in each cooling water
situation, along with various comments and clarifications. For simplicity, only
current plant sites and reactors are included in Table 3-1 below. New plant data
are included in Attachments A, B and C.
Table 3-1
Number of U.S. Nuclear Plant Sites, Organized by Cooling Water Situation
Situation
Number
1A
1B
3
4
5
6
Situation Description
Site uses wet closed-cycle cooling towers at all
reactor units on that site (natural draft,
mechanical or combination)
Site uses once-through cooling on a man-made
cooling pond that has been judged to not be a
waters of the U.S. and thus exempt from
EPAs CWA 316(b) requirements. These sites
are treated under the CWA as functionally
equivalent to closed-cycle cooling tower plants
(Situation 1A above)
Site uses once-through cooling on a man-made
cooling pond that has been judged to be
waters of the U.S. and thus not exempt from
EPAs CWA 316(b) requirements.
Site uses once-through cooling on a multipurpose reservoir (in-line with source river)
Site uses once-through cooling on an ocean, or
bay that is open to the ocean (i.e., with ocean
salinity levels)
Site uses once-through cooling on an estuary or
tidal river
Site uses once-through cooling on a freshwater
river (free flowing)
Number
of Sites
Number of
Reactors
22
32
(+2)*
10
15
(-1)*
11
11
9
(-1)#
TOTALS
65
104
* Two sites with both a closed-cycle cooled unit and a once-through cooled unit are
listed under the applicable once-through category. This applies to Nine Mile Point
(Situation 7) and Arkansas Nuclear One (Situation 3), where the older unit is oncethrough cooled and the newer unit uses a natural-draft cooling tower. When these site
data are summed on an individual reactor basis, the data are adjusted to add two
reactors to the Situation 1A total and subtract one each from Situations 3 and 7.
7
Site uses once-through cooling on a Great Lake
3-2
It should be recognized that the number of sites in Situations 2-7 are a subset of
the total number of sites in each category. For example, the six sites listed for
Situation #7 (once-through cooling on a Great Lake) are not the total number of
reactor sites on the Great Lakes. Per Attachment A, there are a total of 13
reactors on ten sites on the Great Lakes. Of these ten sites, six are in Situation 7
and four are in Situation 1A. Situation 1A is not broken down by waterbody
type.
In order to answer the question, How many U.S. reactors are once-throughcooled and how many are closed-cycle-cooled, some conventions or rules were
established. For purposes of this report, the following rules are used to classify
reactors into the above situations:
The closed-cycle cooled category includes all reactors that are cooled
exclusively (100%) by either cooling towers (Situation 1A) or a cooling pond
that is exempt from 316(b) requirements (Situation 1B).
Plants that are cooled by a cooling pond that has not been determined to be
exempt from 316(b) are treated as once-through.
Plants that have cooling towers that do not provide all cooling needs at 100%
power at all times of the year (e.g., plants with helper towers or seasonal
towers) are categorized as once-through. This includes a few plants that use
towers extensively for large portions of the year or that have large capacity
towers that can provide a majority (but not all) of the required cooling. This
rule is based on the fact that helper towers typically reduce discharge
temperatures but dont reduce flow rate through the intake structure. Note
that the EPAs proposed 316(b) rule considers these plants to be oncethrough cooling facilities.
Plants whose condensers are closed-cycle cooled, but that use once-through
cooling for small or auxiliary site heat loads (e.g., essential service water) are
retained in the closed-cycle category. This is reasonable, since the required
flow rates for these smaller systems are typically less than the makeup flow
rates to a closed-cycle cooling system for the condenser.
Based on these assumptions, cooling categories for the U.S. reactor fleet are
summarized here in Table 3-2:
Table 3-2
Summary of U.S. Nuclear Power Plant Cooling System Types
Cooling Mode
Total Reactor Count
Percentage
Once-Through Cooling
62
59.6
Closed-Cycle Cooling
42
40.4
104
100.0
TOTALS
Note that on a site basis (not on an individual reactor basis), the total number of
sites in Situations 2 through 7 (once-through cooled sites) is 39. This summation
3-3
of once-through sites appears in Attachment C and appears frequently in

subsequent chapters in this report.
Following are statistics on types of cooling towers selected for U.S. nuclear power
plants:
Of the 34 reactors in the U.S that use cooling towers (Situation 1A), 20 of
them use natural draft cooling towers, 13 use mechanical draft towers, and
one (Grand Gulf) uses both.
Of the 11 reactors that are once-through cooled but use helper towers, nine
use mechanical towers, and two (Sequoyah 1&2) use natural draft towers.
Of the 26 planned reactors with COL or ESP applications before the NRC,
13 reactors plan to use mechanical towers, nine plan to use natural draft
towers, and four plan to use cooling ponds exempt from 316(b)
requirements. Two of the reactors planning to use mechanical towers also
plan to use municipal effluent for makeup. In addition, Watts Bar-2,
currently back under construction, already has a natural draft tower
constructed.
3.1.2 Summary of Key Differences between Fossil and

Nuclear Facilities
In general, cooling system designs and operations are quite similar between fossil
and nuclear facilities. A few subtle differences exist as highlighted below:
1. A larger percentage of nuclear plants rely on once-through cooling than is
the case for fossil plants. Over 60% of the current fleet of fossil plants in the
U.S. uses closed-cycle cooling. In contrast, only 40% of the nuclear fleet uses
closed-cycle cooling.
2. As discussed in Chapter 5, the water withdrawal and water consumption
rates for nuclear plants are slightly higher than for fossil plants. This is
because fossil plants operate at higher steam temperatures and pressures and
therefore achieve slightly higher cycle efficiencies. The difference in
efficiency ranges from 2-3% in relation to coal plants and roughly 10% for
gas fired plants. In addition, fossil plants expel some of their waste heat up
the stack.
3. All nuclear plants are baseloaded, and because of their low production costs,
first to dispatch to the grid. This asset, in addition to nuclear plants high
reliability and performance statistics, results in average capacity factors for
nuclear energy in excess of 90%. In contrast, although some fossil facilities
have capacity factors similar to nuclear facilities, coal plants operate on
average at about a 70% capacity factor, and natural gas/combined cycle plants
7
Includes data from three units that have filed COLAs but have subsequently deferred
construction, since these filings are still useful in assessing utility choices for preferred cooling tower
technology.
3-4
at about 50% or less.8 The impacts of this first to dispatch status for nuclear
plants on cooling water issues are many. Among them are practical
limitations on fish protection technologies. As discussed in Chapter 7, there
are a number of alternative technologies for minimizing potential adverse
impacts on aquatic life, including exclusion devices, traveling screens,
diversion systems, relocation of intake structures (e.g., to deeper water or
locations further from shore where fish population densities are lower). Some
of these technologies are close-to or equally as effective as cooling towers in
reducing impingement and/or entrainment, depending on site specific
characteristics and affected species. However, some of these alternative
technologies involve cooling water flow reductions (variable speed pumps
and/or seasonal operations, both of which allow reduced flow or plant
shutdown during sensitive periods to aquatic life such as spawning season).
These flow reduction strategies are not practical options for nuclear plants,
which typically operate at 100% power throughout the year, shutting down
for 2-3 weeks every 18 or 24 months for refueling.
Figure 3-1
USGS Water Resource Regionsi
Note: gray lines are state lines, blue lines are major rivers, white lines are waterresources region boundary lines.
8
These data are from the latest EIA Annual Report (2010). Anecdotal data suggest that todays
natural gas prices are allowing combined cycle plants to dispatch ahead of coal in many parts of the
country, suggesting that NGCC could move ahead of coal in capacity factor in 2011 or 2012.
3-5
Table 3-3
Number of U.S. Reactors by USGS Water Resources Region
Region #
Region Name
# Operating
reactors
# new reactors
(w/COLA or ESP)
--
New England
Mid-Atlantic
19
South Atlantic-Gulf
23
12
Great Lakes
13
Ohio
--
Tennessee
(Watts Bar-2 completion not counted here)
Upper Mississippi
15
--
Lower Mississippi
--
Souris-Red-Rainy
--
--
10
Missouri
--
11
Arkansas-White-Red
--
12
Texas-Gulf
13
Rio Grande
--
--
14
Upper Colorado
--
--
15
Lower Colorado
--
16
Great Basin
--
--
17
Pacific Northwest
--
18
California
--
Alaska/Hawaii
--
--
Caribbean
--
--
104
20
19/20
21
TOTALS
----

Cooling Worldwide
3.2.1 Summary of Nuclear Power Plant Data
Data on international application of once-through cooling vs. closed-cycle
cooling at current nuclear power plants are presented in Appendix D. These data
display a sharp contrast between U.S. regulations and policies and those of other
nations. The data not only differentiate between once-through cooling vs. closedcycle cooling applications, but also differentiate between nuclear plants cooled by
fresh water vs. saline water (i.e., plants sited on oceans, estuaries, and tidal rivers
(O/E/TRs)). Note that many countries with significant nuclear plants are landlocked, without access to ocean cooling (e.g., Ukraine), while others, like the
U.S. and France, have access to both types of cooling. Eight countries rely
exclusively on ocean water for once-through cooling of their nuclear plants:
3-6
Japan, South Korea, the UK, Sweden, Brazil, Finland, and South Africa. A
summary of Appendix D data follows:
Table 3-4
International Data on Use of Once-Through Cooling and Closed-cycle Cooling
Modes in Fresh and Saline Water
Nuclear Plants
Fresh
Water
Closedcycle
cooling
Saline
Water
(O/E/TR)
Closed-cycle
cooling
Fresh
Water
Oncethrough
cooling
Saline Water
(O/E/TR)
Oncethrough
cooling
non-US totals, by %
24%
0%
26%
50%
US totals, by %
39%
1%
39%
21%
3.2.2 Observations and Insights from International Data

The above data show that the U.S. relies much more on fresh water for nuclear
plant cooling and less on saline waterbodies (i.e., O/E/TRs) than other nations,
by over a factor of two. The data also show that the U.S. relies much more on
closed-cycle cooling and much less on once-through cooling for its nuclear plants
than other nations, by a factor of about 1.7. Countries with geographic access to
oceans preferentially site thermoelectric plants on O/E/TRs, if available, in large
part to take advantage of the cooler water for efficiency reasons, but also to
preserve limited and valuable inland fresh water resources for other water users
(e.g., municipal water supply, agriculture).
Also note that a recent report by EPAs counterpart agency in the UK [Ref. 5]
favors once-through cooling as BTA, even in O/E/TR siting situations: the
findings of our study indicate that direct cooling can be Best Available
Technology (BAT) for estuarine and coastal sites, provided that best practice in
planning, design, mitigation and compensation are followed. We therefore
conclude that direct cooling may be the best environmental option for large
power stations sited on the coast or estuaries, subject to current best planning,
design and operational practice and mitigation methods being put in place, and
meeting conservation objectives of the site in question.
Also note that Electricite de France (EDF) has embarked on a strategic initiative
on water partitioning Frances term for long range planning among
competing users of fresh water resources. EDF uses computer models of future
environmental impacts of climate change on diminished fresh water resources as
the quantitative basis for this long-term planning effort.
In the U.S., all once-through-cooled nuclear plants withdrawing cooling water
from oceans, estuaries, or tidal waters were granted construction permits in the
1964-1977 timeframe. Since then, no nuclear plant has been sited on such waters
with the exception of Hope Creek. Hope Creek (construction permit in 1974;
commercial operation in 1986) uses a cooling tower. All ESP and COL
applications filed with NRC over the last decade (6 ESP sites and 18 COLA
3-7
sites) will use cooling towers, and all but two will use fresh water for cooling. The
two exceptions are: PSEGs Salem/Hope Creek site (ESP on a tidal river), and
Calvert Cliffs-3 (COLA on an estuary). Turkey Point 6/7 is on an ocean, but
will use Dade County municipal waste treatment plant effluent [exempt from
316(b)] and cooling towers for cooling, similar to Palo Verdes arrangement with
the City of Phoenix.
Cooling for New U.S. Facilities
3.3.1 Projected Growth in Nuclear Energy in the U.S.;
Implications to Cooling Water
Expansion in the nuclear industry is occurring in three dimensions, all of which
impact water use. New plants will add demand for more cooling water. Power
uprates of existing reactors require incrementally more water, which in some
cases translates to a modification to a plants water permit and/or capacity of its
cooling system. License renewal of existing facilities means that arrangements for
water use need to be extended further into the future, potentially in the face of
competing demands for that water.
The nuclear power industry continues to make progress toward the construction
of new nuclear power plants in the U.S. To date, companies have submitted 16
license applications to the NRC for 25 new reactors. Twelve of these
applications, representing 20 new reactors, are currently under active review. Of
these, approximately 80% are on existing sites and 20% are on new sites.
Combined operating licenses have been issued very recently by NRC for
Southern Companys Vogtle Units 3 and 4, and SCANAs Summer Units 2 and
3, all using the recently approved Westinghouse AP1000 reactor design. The
nuclear industry expects 4-8 new reactors in commercial operation by 2020.
Since 2000, the NRC has authorized 92 power uprates, yielding a cumulative
capacity increase of 4,227 MWe. The NRC is currently reviewing 18 applications
for uprates, totaling about 1,453 MWe of capacity. Over the next five years, the
NRC anticipates that companies will apply for power uprates that could
represent an additional 1,199 MWe of new capacity. The cumulative effect of
these additions will average out to almost 70 MWe per reactor, or about a 7%
increase on average in output for each unit. This in turn is roughly equivalent to a
7% increase in water usage (or somewhat less, if some plants have the flexibility
to adjust cooling water discharge temperatures slightly upward).
Starting in 2000, the NRC began approving 20-year renewals of nuclear power
plants 40-year licenses, allowing those plants to operate for a total of 60 years.
Since then, NRC has approved license renewals for 71 nuclear reactors, and has
under active review requests for another 15 applications for renewal. Owners have
formally announced intent to file application for renewal for an additional 17
reactors, leaving only one U.S. reactor that has not yet announced its intent to
file (the newest one). Further, industry and DOE have initiated efforts to define
the necessary R&D to support a further life extension beyond 60 years for U.S.
3-8
reactors (e.g., to 80 years or more). DOE and industry are working closely with
NRC to ensure these efforts meet NRC requirements. If successful, these efforts
would result in plant lives of at least 40-50 years beyond the average age of
todays plants.
All of these opportunities for growth new plants, power uprates for existing
plants, and life extensions of existing plants have implications to cooling water
issues. Although utilities can reasonably predict regional power demands and
associated cooling water needs a decade or more into the future, it is much more
difficult for any nuclear plant owner to predict today what the competing
demands for water will be at a specific site 60 to 80 years into the future. The
only certainty is that water use demands are destined to grow in the future, not
diminish.
Another nuclear power plant deployment option being considered by industry
and DOE are Small Modular Reactor (SMR) concepts, currently being
developed for licensing in this decade. Small-scale reactors can complement large
nuclear plant projects by expanding potential markets in the U.S. and abroad for
low-carbon energy production. Their small size (less than 300 megawatts), make
them well-suited to replace older fossil generating capacity, taking advantage of
existing transmission and cooling water infrastructure.
3.3.2 Options for Cooling Water Strategies for New Reactors
on Existing Sites in the U.S.
Expansion of nuclear energy in the U.S. will rely heavily on existing nuclear sites.
The following provides some rough estimates of the potential for building new
reactors on existing sites:
There are a number of existing sites with currently operating reactors that
were originally planned and laid out in the 1960s or 1970s for more reactor
units than were ultimately built. Situations where an order was placed but
then cancelled are indicative of situations where new construction is possible
today on a proven site issues of land availability, adequacy of water and
transmission were previously resolved, and may remain within acceptable
parameters today. There are 27 previously planned reactors on 19 sites in this
situation. Nine reactors are now actively proceeding in the new plant
licensing process (COL, ESP, or Part 50) on these sites, with two more
reactors in suspended COLA review status.
There are a number of existing nuclear sites with adequate space for new
units, even though no formal plans or orders or construction permits were
ever executed for additional units on these sites. In fact, seven of these sites
have been selected for new plant construction in this decade, with 11 reactors
proceeding through the new plant licensing process in this situation. These
11 reactors are in addition to the ones identified in the previous bullet.
In addition to above, there are roughly 10 to 15 existing sites with currently

operating reactors that neither have a history of prior plant orders nor any
current plans to initiate new plant licensing, but that in theory should have
3-9
sufficient space, infrastructure, and regional power demand to support

additional reactors.
In summary, about 40 of the 65 existing nuclear plant sites are either currently
pursuing new plant licensing for that site, or have previously evaluated additional
units for that site, or could, in theory, consider additional units for that site. This
finding, in combination with the important statistic noted earlier that 80% of all
active new plant licensing applications are for reactors on existing sites, clearly
demonstrates the importance of existing nuclear plant sites to the expansion of
nuclear energy in the U.S. This conclusion is not surprising. Existing sites
typically have significant advantages over greenfield sites: established
infrastructure including transmission access, exhaustive regulatory review of site
characteristics important to reactor safety and environmental protection (e.g.,
seismicity and water resource characterization, respectively), state and local
understanding of nuclear issues and associated licensing, permitting, and
emergency planning processes. Consequently, these trends suggest that roughly
60% to 80% of new nuclear capacity would be constructed on existing sites.
However, it is important to recognize the challenges associated with siting new
reactors on existing nuclear sites, relative to cooling water issues. This is
especially true if cooling towers are mandated for retrofitting on current plants or
are mandated for new plants on existing sites. These questions are the subject of
the proposed rule discussed in the previous chapter.
In the proposed rule, EPA discusses the impacts of its requirements for new units
on existing sites. For purposes of analysis, EPA established a value of 30% as the
portion of new capacity that would be constructed at existing facilities based
exclusively on fossil trends:
In the Phase I Rule analysis, EPA determined that 76% of new coal
and 88% of new combined cycle capacity would be constructed at new
greenfield facilities and would be subject to Phase I requirements
while the remainder (24% of coal and 12% of combined cycle) would
occur at existing facilities and be subject to existing facility regulations.
EPA has selected a conservative value of 30% reflecting both coal and
combined cycle to serve as an estimate for the portion of new capacity
that would be constructed at existing facilities. At existing nuclear
facilities, only new capacity associated [with] the construction of new
generating units would be subject to the new unit requirements.
Considering their size and heat discharge as well as recent trends in
industry, it is assumed that any new nuclear units will utilize closedcycle cooling and so the capacity for these nuclear facilities is not
included in the costs of requirements for new units.9
3-10
Section 4: Comparison of Closed-Cycle

Cooling Retrofits versus OnceThrough Cooling
This chapter discusses a number of tradeoffs associated with once-through versus
closed-cycle cooling. These include the environmental impacts associated with
these technologies, cost and supporting infrastructure issues. One potentially
significant environmental impact is evaporative water loss in fresh waterbodies;
this topic is discussed separately in Chapter 5.
4.1 Once-through Cooling
Initially, once-through cooling was the standard for thermoelectric power plants.
However, concerns developed over the effects of thermal discharges and later
over cooling water intake structure (CWIS) effects. Statutory requirements were
included in the Clean Water Act that resulted in a general shift to use of closedcycle cooling systems for new power plants. This was especially the case where
there was interest in siting larger generating facilities on smaller waterbodies. In
2001 EPA promulgated 316(b) regulations for new generating stations to address
CWIS impacts. Those regulations designated closed-cycle cooling as BTA for
new generating stations, but set a performance standard that would allow oncethrough cooling if a proposed facility demonstrated it could achieve a level of fish
protection within 10% of the 90% level of protection that could be achieved with
There are a number of advantages associated with the use of once-through cooled
plants that include:
They generally achieve more efficient condenser cooling as a result of

supplying the condenser with colder water than can be achieved with closedcycle cooling.
They are significantly less expensive than closed-cycle cooling due to the
avoided one-time capital cost of the cooling tower, avoided energy
requirements of the cooling tower during operations, periodic maintenance of
the cooling tower, and the reduced heat rate during operations.
They avoid a number of potentially significant adverse environmental

impacts discussed in Section 4.2.3 of this chapter.
4-1
They consume much less water, as discussed in Chapter 5.
The two major advantages of closed-cycle cooling are the significant reduction in
the thermal discharge, and reduced fish and shell fish mortality associated with
the CWIS (i.e., impingement and entrainment mortality). As discussed later, the
impingement and entrainment impact losses may be measurable in the
immediate vicinity of the plant, but rarely are impacts measurable in the larger
source waterbody.
EPAs 316(b) new facility rule allows use of once-through cooling under its
Track 2 as long as a level of fish protection can be achieved that is within 90%
of that which can be achieved with closed-cycle cooling. The EPA Proposed
316(b) Rule for existing facilities does not designate closed-cycle cooling as BTA
for impingement. For entrainment, the BTA decision is made on a case-by-case
basis by the permitting authority as to whether or not closed-cycle cooling is
BTA. Note that Options 2 and 3 do designate closed-cycle cooling as BTA.
4.2 Closed-cycle Cooling
As discussed in Chapter 3, closed-cycle cooling is currently used on 42 of the 104
nuclear units in the U.S. Of these, 34 use wet cooling towers (13 mechanicaldraft towers; 20 natural-draft towers, and one unit that uses both) and eight use
cooling ponds or cooling lakes that are treated as closed-cycle systems for
purposes of 316(b). Plants on cooling ponds that dont qualify as exempt from
316(b) are considered once-through cooled plants. The several system types were
described and discussed in Section 2.3.
4.2.1 Closed-cycle Cooling for New Facilities
As noted earlier, closed-cycle systems have a higher capital cost, and impose
larger unit output reductions than would a once-through cooling system on an
identical unit. EPRI has recently completed a study on cost/performance
comparisons among alternative closed-cycle cooling systems. The study covered
the three major closed-cycle cooling categories of recirculating wet cooling, dry
cooling and hybrid cooling as applied to coal-fired steam plants, gas-fired
combined-cycle plants and nuclear plants. The results of that study are discussed
in Section 4.3.
4.2.1.1 Different Cooling Systems for New Facilities
Recirculating wet cooling: Wet cooling systems, comprised of a shell-and-tube
surface steam condenser and a wet cooling tower, are described in Sections 2.3.1
and 2.3.2. Nearly all the cooling towers installed in recent years have been
mechanical-draft towers (Section 2.3.1). Natural-draft towers (Section 2.3.2)
were popular 20 to 40 years ago particularly for large, base-loaded plants
including many nuclear plants. None had been built in the U.S for approximately
20 years until a recent installation at a fossil plant retrofit in southeastern
Massachusetts. As discussed in Chapter 3, about 1/3 of the new nuclear plants
under review by NRC for construction in the U.S. plan use of natural draft
4-2
towers. Recirculating wet cooling systems are likely to continue to be the

commonly chosen system for both fossil and nuclear plants, primarily in response
to 316 requirements. Some special circumstances may dictate the use of waterconserving systems at fossil sites, even in water-rich areas. Nuclear plants will
generally be sited where adequate water resources are available.
Recirculating wet cooling systems are characterized by cold water temperatures
approaching the wet bulb temperature of the atmosphere, water consumption
rates in the range of 10 to 15 gpm/MW (including typical blowdown rates; or 8
to 12 gpm/MW, if estimated exclusive of blowdown), and moderate costs in the
range of $6,000 to $10,000/MW.
Dry cooling: All the dry cooling systems installed in the U.S. are direct dry
cooling of fossil plants in which steam from the turbine exhaust is ducted directly
to an air-cooled condenser. These systems are described in Section 2.3.3. While
natural-draft designs of air-cooled condensers are possible, none have been
installed in the U.S., and relatively few have been used elsewhere in the world.
The number of dry cooling systems has increased substantially in the U.S. for
fossil plant applications since the late 1970s as indicated in Figure 4-1 but the
total plant capacity using dry cooling is still a small fraction of the utility industry
capacity on closed-cycle cooling. The continued use of dry cooling on some new
fossil plants is likely, particularly in the high population growth areas of the
Southwest. As discussed in Chapter 2, dry cooling is not currently considered a
practical option for nuclear plants.
Cumulative Capacity, MW
ACC Installed Capacity
Year of Commercial Operation

Figure 4-1
Dry cooling installations in the United States by year (Ref. 6)
4-3
Dry cooling systems are characterized by essentially zero water use, elevated
turbine exhaust pressures on hot days, higher operating power requirements than
the recirculating wet systems and higher capital costs, ranging from 3 to 5 times
that of wet cooling.
Hybrid wet/dry cooling: Hybrid cooling systems consist of wet and dry elements
which can be used separately or in conjunction with one another as conditions
dictate. The typical wet/dry parallel configurations were described in Section
2.3.4. Only three such systems have been installed on new plants in the U.S. and
all three have been of that design. Two of the plants are relatively small gas-fired,
combined-cycle plants; the third, a large coal-fired steam plant. No hybrid
systems have been installed to date on a nuclear plant, although such a system has
been reviewed as an option for most new nuclear plants, and has been included in
plans for one plant (see Chapter 2 for details on North Anna-3). Hybrid cooling
systems have been designed to conserve as much as 20-80% of the water
consumed in wet cooling systems. Use of these systems has been adopted where
stakeholder involvement or permitting requirements have required a reduction in
the amount of water consumed by the facility.
4.2.1.2 Cost/Performance Comparisons for Closed-cycle Cooling Systems
for New Plants
A recent EPRI report [Ref. 7] provides a detailed study comparing the costs,
water requirements, and the annual energy production of fossil and nuclear plants
equipped with wet, dry and hybrid cooling systems. The results for the three
plant types are shown in tabular form in Table 4-1. The same results are shown
in graphical form for nuclear plants in Figure 4-2.
4-4
Table 4-1
Cost performance comparisons for alternative cooling systems at three plant types
at five representative sites (Ref. 7)
COAL FIRED STEAM PLANT
Jacksonville
Bismark
Yuma
Cooling
System
MWh kgal
MWh kgal
MWh kgal
Burlington
$
MWh kgal
St. Louis
$
MWh kgal
x10^6 x10^6 x10^6 x10^6 x10^6 x10^6 x10^6 x10^6 x10^6 x10^6 x10^6 x10^6 x10^6 x10^6 x10^6
Wet
3.56
4.40
2.18
Dry direct
18.10
4.10
0.00 15.00 4.19
0.00 11.60 4.21
0.00 11.70 4.20
0.00 13.60 4.20
0.00
Dry indirect 31.00
4.10
0.00 25.00 4.17
0.00 18.30 4.27
0.00 18.50 4.23
0.00 21.20 4.20
0.00
4.27
1.32 12.40 4.29
0.87 10.30 4.32
0.46 9.90
0.47 11.30 4.30
0.72
Hybrid
13.50
3.59
4.40
1.91
3.39
4.40
1.67 3.41
4.40
4.32
1.72
3.56
4.40
1.79
NUCLEAR STEAM PLANT

Yuma
Cooling
System
Wet
Bismark
Jacksonville
MWh kgal
MWh kgal
Burlington
MWh kgal
MWh kgal
St. Louis
$
MWh kgal
4.66
5.21
3.49
5.22
2.86
Dry indirect 39.70
4.86
0.00 28.50 5.03
0.00 24.60 5.06
0.00 24.60 5.06
0.00 28.80 5.00
0.00
5.03
2.42 30.70 5.03
1.68 26.00 5.08
0.96 26.50 5.08
0.98 28.00 5.06
1.46
Hybrid
30.60
4.7
5.19
3.05
4.39
5.23
2.64 4.42
5.23
2.74
4.62
GAS-FIRED, COMBINED-CYCLE
Yuma
Cooling
System
Jacksonville
MWh kgal
MWh kgal
Bismark
$
Burlington
MWh kgal
MWh kgal
St. Louis
$
MWh kgal
Wet
1.70
4.46
1.17
1.70
4.56
0.98
1.64
4.56
0.82 1.63
4.56
0.83
1.67
4.56
0.92
Dry direct
8.77
4.55
0.00
7.10
4.55
0.00
6.60
4.55
0.00 6.40
4.55
0.00
7.90
4.55
0.00
Hybrid
6.90
4.64
0.85
6.30
4.56
0.54
5.00
4.56
0.23 5.00
4.56
0.22
5.70
4.56
0.36
Figure 4-2
Cost performance comparisons for nuclear plants at five representative sites of
differing meteorology (Ref. 7)
4-5
The cost comparisons above focus on differences among wet, dry, and hybrid
closed-cycle cooling technologies. No recent quantitative studies that compare
the relative costs of wet closed-cycle cooling to once-through cooling are
available. As discussed in the next section, the cost and related penalties of
closed-cycle cooling are both much higher for retrofits than for new plants.
Stated differently, the cost differential for new plants between once-through
cooling and closed-cycle cooling is much smaller than for the retrofit case. Thus,
the requirements of the CWA Phase 1 rule discussed in Chapter 2 that strongly
favor closed-cycle cooling for new plants, does not create a huge issue for new
plants from a cost perspective (in contrast to the retrofit scenario), all other
factors being equal. The practical implication of this cost contrast is that the
Track 2 option available in the Phase I Rule has been rarely used.
This does not mean that the cost differences between once-through cooling and
closed-cycle cooling for new plants are zero. Clearly, the cost penalties associated
with closed-cycle energy requirements (e.g., fans) combined with the heat rate
penalty, apply to new plants, resulting in a net reduction in plant efficiency of 24%, with its associated cost penalty.
Capital costs for closed-cycle cooling would also be somewhat higher than for
once-through cooling, although the differences are relatively small compared to
total plant cost. Higher capital costs for closed-cycle cooling are associated with
the cost of cooling towers and a larger condenser. Higher costs for once-through
cooling are associated with larger circulating water pumps and larger CWISs.
4.3 Cooling System Retrofits for Existing Facilities
4.3.1 Costs of Retrofits
It is widely understood [EPA Ref. 8; EPRI Refs. 9-14, DOE Ref. 15] that the
cost and related penalties of closed-cycle cooling are much higher for retrofits
than for new plants. EPRI recently published a detailed study [Ref. 9] of retrofit
costs assuming a common approach to retrofit illustrated schematically in Figure
4-3.
Figure 4-3
Schematic of closed-cycle cooling retrofit arrangement
4-6
The primary assumptions in the EPRI study were:

1. The original condenser and circulating cooling water flow rate remain
unchanged
2. The cooling tower will be a counterflow, mechanical-draft tower
EPRI identified ten cost elements that would make up the total cost to retrofit
should closed-cycle cooling be designated BTA for the industry. These cost
elements were:
1. Cooling tower capital cost (hardware and construction cost)
2. Cost of capital to finance the project
3. Revenue loss for extended outages to tie in the cooling tower system
4. Energy penalty (lost revenue due to energy requirements for cooling tower
fans and pumps)
5. Heat rate penalty (lost revenue due to reduced condenser cooling efficiency
with a cooling tower compared to once-through cooling)
6. Operating and maintenance cost (labor and materials to operate and
maintain the closed-cycle system)
7. Permitting costs
8. Cost of replacement power generation (replacement power to offset loss of
generation due to premature facility retirement in response to economic or
permitting issues)
9. Cost of electric system upgrades (upgrades to the electric system due to
generation losses from the energy penalty, heat rate penalty, prematurely
retired facilities) as a result of shifting voltage loads to the transmission
system that may not be designed for the new loads
10. Environmental and social costs (e.g., monetized costs to avoid environmental
effects of closed-cycle cooling such as noise, drift, habitat loss, increased
consumptive water loss).
Cost elements 1-7 are facility specific costs that would reasonably be considered
by each facility in making the economic decision on whether or not to retrofit.
Cost elements 8 and 9 are costs that would be borne by the industry as a whole
and cost element 10 represent social costs that would be borne by populations in
proximity to the closed-cycle system. A summary of those costs for the 39 oncethrough cooled nuclear facilities is provided below.
Data from a number of independent sources, including actual retrofits and
detailed engineering studies by utility engineering departments and established
A&E firms gave a range of retrofit capital. These costs had the following
features.
1. For plants of comparable capacity, the costs for nuclear units exceeded those
for fossil units
4-7
2. At a given circulating water flow rate, there was typically a wide range of
costs which were assumed to correspond to retrofits of varying degrees of
difficulty determined by site-specific factors
3. For plants of similar difficulty, the costs were generally scalable linearly with
circulating water flow rate.
4.3.1.1 Capital Cost
EPRI completed a study to estimate the cost of retrofitting the existing oncethrough cooling generating units to inform the 316(b) Rulemaking [Ref. 9]. In
that study estimates were made of the capital cost to retrofit both fossil and
nuclear facilities. The study approach was to construct a model based on a
relatively high degree of correlation between a number of site-specific closedcycle cooling retrofit cost estimates and the volume of cooling water flow. Of the
39 nuclear facilities, 16 facilities (41%) had conducted site-specific retrofit cost
estimates. Based on correlations, cost coefficients were established for both
nuclear and fossil facilities to retrofit cooling towers.
The cost coefficients for the four degrees of difficulty for fossil plant retrofits are:
Easy:
Average:
Difficult:
More Difficult:
$181/gpm
$275/gpm
$405/gpm
$570/gpm
The cost coefficients for the two degrees of difficulty for nuclear plant retrofits
are:
Less difficult:
More difficult:
$274/gpm
$644/gpm
The results showed that in general nuclear facilities were significantly more
difficult to retrofit than fossil facilities. The EPRI study identified eleven factors
that could result in a higher or lower normalized retrofit cost ($/gpm) for any
specific facility. These factors included:
1. The availability of a suitable on-site location for a tower(s)
2. The separation distance between the existing turbine/condenser location and
the selected location for the new cooling tower(s)
3. Site geological conditions which may result in unusually high site preparation
or system installation costs
4. Existing underground infrastructure which may present significant
interferences to the installation of circulating water lines
5. The need to reinforce existing condenser and water tunnels
6. The need for plume abatement
7. The presence of on- or off-site drift deposition constraints
4-8
8. The need for noise reduction measures

9. The need to bring in alternate sources of make-up water
10. Any related modifications to balance of plant equipment, particularly the
auxiliary cooling systems, that may be necessitated by the retrofit
11. Re-optimization of the cooling water system.
Based on these factors and information provided by facilities, EPRI conducted a
Best Professional Judgment (BPJ) evaluation of 125 facilities including 10
nuclear facilities to estimate the capital cost to retrofit these facilities. Additional
estimates were made of other costs related to retrofits including additional
operating power, the cost of reduced unit efficiency and the cost of downtime
during the retrofit process.
The results of that study are documented in detail in [Ref. 7]. The national
retrofit costs, aggregated separately for fossil and nuclear are presented in tabular
form in Table 4-2 below.
The total national capital cost of retrofitting all eligible facilities exceeds $62
billion. The annual costs of additional operating power and reduced plant output
due to cooling system limitations as well as one-time capital costs and revenue
losses during the downtime required to accomplish the retrofits exceeds $95
billion on a net present value basis. Nuclear plants account for 19% of the
capacity of the family of Phase II facilities, but over 30% of the national capital
costs of retrofit (i.e., $32 billion).
Table 4-2
Summary of national retrofit costs (from [Ref. 7], Figure 9.1)
Additional observations are:
In general, retrofitting existing once-through cooled plants with closed-cycle

cooling using cooling towers is much more difficult and costly than installing
closed-cycle cooling at a new, greenfield site. This can be due to a variety of
factors including limited space availability, underground interferences to the
installation of circulating water piping, the need to relocate existing
4-9
equipment and structures and the need to modify and upgrade existing
circulating water intake/discharge structures and tunnels.
There is a wide range for the cost of a retrofit depending on site-specific

factors. Independent data sources indicated capital retrofit costs for fossil
plants ranging from $181/gpm to $570/gpm, a factor of 3.2; for nuclear
plants the range was from $274/gpm to $644/gpm, a factor of 2.6.
The combination of the additional operating power requirements and the

reduced plant efficiency are estimated to effectively reduce the available
capacity of the family of Phase II plants by just over 3% or almost 10,000
MW.
Additional capacity will be lost during the years in which the retrofit projects
are underway due to extended outages at some plants where extensive
modifications to the existing equipment are required. In aggregate this could
result in the need to replace about 500,000 GWh from other sources or over
10% of the national power systems output from fossil and nuclear steam
plants.
Some facilities will be unable to retrofit primarily due to severe space

constraints.
Attachment E, EPRI National Cost Estimate for Retrofit of U.S. Power Plants
with Closed-Cycle Cooling: Technical Brief Clean Water Act Fish
Protection Issues, dated January 2011 provides a brief summary of EPRIs
closed-cycle retrofitting report [Ref.9].
4.3.1.2 Extended Outages
A potentially significant cost associated with retrofits is the lost revenue from
extended outages that may be required to connect the closed-cycle cooling tower
to the condenser. For many fossil facilities this will not be an issue as many units
serve only as peaking or cycling units to meet peak energy demand and do not
operate for much of the year. However, nuclear units are all baseloaded with
capacity utilization ranging around 90% or more. One nuclear facility, Diablo
Canyon, based on a detailed study [Ref. 16] determined that a 17 month dualunit outage would be required as a result of site-specific difficulties, with an
estimated $1.8 billion cost for the lost revenue. The capital cost for the retrofit
was estimated at $2.7 billion in 2008 dollars, for a total capital plus power
replacement cost of $4.5 billion. Also, because the nuclear facilities are
baseloaded with most having a relatively long remaining life, most would likely
optimize the condensers for closed-cycle cooling to reduce the energy penalty.
EPRI estimated that an average outage duration of 6 months would be required
to retrofit nuclear facilities as a result of site-specific difficulties and/or condenser
optimization. This would result in an estimated lost revenue cost of $8.3 billion
for the 39 nuclear generating stations.
4-10
4.3.1.3 Plant Efficiency

Retrofitting from once-through cooling to closed-cycle cooling results in a net
reduction in generating efficiency. This is due to the need for some of the
generated output to operate the fans in the case of mechanical draft cooling
towers and the large pumps needed to pump cooling water to above the cooling
tower fill, and the loss of generating efficiency experienced at most units due to
the increased heat rate (i.e., the cooling tower cannot cool the water to as low a
temperature as supplied from the source waterbody). Each of these factors is
discussed.
4.3.1.3.1 Retrofit Energy Requirements
EPRIs Closed-cycle Cooling Research Program estimated the additional
operating costs for cooling tower fans and pumps required for mechanical draft
closed-cycle cooling systems. The gross annual O&M cost estimate was based on
the assumption that the sum of the additional required operating power for the
additional pumping head and the cooling tower fans ranged from 0.9 to 1.7% of
plant output. For fossil plants, the mid-range value of 1.3% or 13 kW/MW was
used. However, for nuclear facilities with an average normalized circulating water
flow approximately 30% higher than fossil plants, the high end of the range, 17
kW/MW, was used. The higher water use for nuclear facilities compared to fossil
facilities is because none of the waste heat generated in the reactor system is
emitted up a stack10 so that all of that heat is transferred to the cooling water. In
addition, the steam temperature and pressure of nuclear units is lower than a
typical fossil unit, so the heat-rate for nuclear plants is inherently lower. Hence,
the thermal cycle in a reactor used to produce electricity is somewhat less efficient
for nuclear than fossil facilities, and the additional waste heat must be removed
by the cooling system.
As discussed in the previous section, most baseloaded nuclear facilities would
likely re-optimize the condensers to reduce the energy requirements. Doing so
would allow the circulating water flow and the tower size to essentially be halved.
Re-optimization involves changing the condenser from the one-pass design
typically used in once-through cooling (high flows, single pass, low 10-20oF
temperature rise) to a two-pass design typically used for closed-cycle cooling
(lower flows, two pass, high 35-45oF temperature rise). With the higher
temperature rise achieved by a two pass condenser, the cooling tower can be
optimized (smaller tower) because of the higher driving force for heat rejection to
ambient air. The two pass condenser design also minimizes the condensate return
temperature, as the coldest water is passed through the bottom pass of the
condenser. In a new system, this would also allow for reductions in circulating
water pipe sizes. This design usually requires that the condenser water boxes be
partitioned, and either the inlet or outlet circulating lines be moved to the
opposite side of the turbine.
Unlike fossil plants, nuclear plants dont have a stack for dispersion of combustion product air
emissions.
10
4-11
These structures are often located below-grade, which further increases the
complexity and cost of such a retrofit. It is much easier to design and build the
balance of plant (BOP) to the plants design parameters and intended cooling
mode than to change it later.
One benefit of re-optimization would be slightly lower capital cost for the
cooling tower, but this would not offset the increased costs for the condenser and
circulating water line modifications. The biggest benefit would be the increased
efficiency achieved by the optimized system for the remaining life of the plant.
This kind of retrofit would be most cost-effective for nuclear plants, since they
would suffer a larger penalty than fossil plants with an unoptimized system. The
large capital investment in re-optimization would likely be amortized over a
longer time period, with a base loaded plant running at 90% or higher capacity
factor.
Assuming that all nuclear plants would re-optimize, 8.5 kW/MW (one-half of
the 17 kW/MW discussed in the previous paragraph) was assumed as the average
operating cost for the nuclear facilities. See Ref. 9 for details on optimization
assumptions.
Based upon the assumptions discussed, the estimated national cost associated
with the energy penalty was $141 million annually for the 60,000 MWs of
nuclear generation and $427 million for the 252,392 MWs of fossil generation.
Thus, while nuclear generation makes up approximately 19% of the total oncethrough cooled generation, assuming all once-through cooled generation were
required to retrofit, the nuclear facilities would bear 25% of the energy penalty
cost.
4.3.1.3.2 Heat Rate Penalty
Because lower condensing water temperatures can almost always be achieved
with once-through cooling than with a closed-cycle cooling system, there is a
heat rate penalty associated with closed-cycle cooling. This penalty results in a
net decrease in the generating capacity for units that use closed-cycle cooling.
The amount of this penalty varies during the course of the year but is greatest
during hot weather summer temperatures, which coincide with the period of
peak seasonal energy demand and energy prices for most regions of the U.S.
A calculation similar to that for the energy requirements can be made of the cost
of the annual energy penalty resulting from the increased turbine backpressure
and reduced turbine efficiency. EPRI [Ref. 9] made these calculations for hot
day and annual average conditions for example sites in seven geographical
regions with differing climates and source waters. They show a wide range
varying from -0.9 to 1.15 inches Hga on hot days with an average of about 0.6
inches Hga and from 0.55 to 1.41 inches Hga with an average of about 0.9
inches Hga at annual average conditions. EPRIs study found the differences
stem from differences in the source water temperature for once-through cooling
and the wet bulb temperature plus the tower approach for closed-cycle cooling.
Based on this information EPRI estimated the aggregated national cost of the
4-12
energy/capacity penalties associated with the heat rate penalty. The average
backpressure increase across the seven regions was used for the hot day and
annual average conditions (see Ref. 9, pg. 18). The output reduction per unit
increase in turbine exhaust pressure, expressed as % reduction per inches Hga,
was assumed to be 1%/inch Hga at annual average conditions and 2%/inch Hga
at hot day conditions. Hot day conditions were assumed to pertain for 10% of
the year (876 hours) and annual average conditions for the remainder of the year
(7,884 hours). The reduced output for baseloaded nuclear facilities (which are
unable to compensate, as some fossil units can, for the energy loss by over firing),
was valued at $35/MWh. For fossil facilities that may be able to over fire, the
same assumptions were made as in the previous section. The result was an
estimated cost for the 60,000 MWs of once-through cooled nuclear generation of
$182 million/yr. and $527 million/yr. for the 252,392 MWs of fossil generation.
The nuclear capacity which comprises 19% of the once-through cooled capacity
incurred approximately 26% of the national annual heat rate penalty cost
estimate.
It should be noted that in some cases, such as in the southeast on small rivers or
in the south central area on small ponds or lakes, the source water temperature in
the summer can exceed the temperature of cold water available from a cooling
tower. Therefore, there can be a net increase in hot day efficiency and output
with closed cycle cooling. These considerations, while rare, were factored into the
establishment of the average penalty.
4.3.1.3 Other Facility Specific Costs
EPRI identified three additional costs that would be incurred but were not
estimated as part of the study. These included the cost of labor and chemicals to
control biofouling and scaling of the cooling towers, permitting costs and the cost
to finance the capital construction. In general these costs would also be expected
to be higher on a per MW basis for nuclear than fossil facilities. The labor and
chemical cost would be greater due to use of approximately 30% more water on
average needed for nuclear facilities than fossil facilities. The permitting costs
would be expected to be higher due to extra layers of regulatory oversight for
nuclear facilities, and the cost of capital would be higher due to the higher
estimated average cost of approximately $457/gpm to cool average nuclear
facilities (33.5% higher than the average cost of $304/gpm to cool fossil
facilities). While none of these costs is considered trivial, these costs are not
considered to be of the magnitude estimated for capital cost, lost revenue for
extended outages and cost of reduced generation output as a result of cooling
system energy requirements and reduced heat rate efficiency.
4.3.1.4 Other Cost Related Considerations
Two important considerations here are: 1) can the nuclear facilities bear the cost
of retrofits, and 2) potential impacts to the electric system. Each is discussed
briefly.
4-13
In the EPRI study of potential financial impacts of a closed-cycle cooling retrofit

requirement [Ref. 10] it was estimated that approximately 26,000 MWs of fossil
generation was at risk of premature retirement for economic reasons if required
to retrofit. For many older units with low capacity utilization the economics
would favor retiring the plant rather than retrofit with closed-cycle cooling, since
they would become even less economical. All of the nuclear facilities are
baseloaded and none was forecast to be prematurely retired. However, the owners
of Oyster Creek (currently the oldest nuclear facility in operation in the U.S.),
under pressure to retrofit cooling towers due to thermal and cooling water intake
structure concerns, announced that the plant would be retired 10 years sooner
than planned to avoid retrofitting with closed-cycle cooling.
EPRIs study of potential impacts of a closed-cycle cooling retrofit requirement
to electric system reliability [Ref. 11] identified a potential risk in 3 of 5 NERC
Regions studied as a result of the premature retirement of the 26,000 MWs of
fossil generation. None of the nuclear units was expected to retire. The result of
the premature fossil unit retirements in the three NERC Regions (ERCOT,
New England ISO and New York ISO) was the potential need for electric
system upgrades as a result of the risk of localized voltage exceedances and/or
security violations. While EPRI modeling did not specifically consider the
downtime associated with the baseloaded nuclear units (Section 4.2.2.1.2) or the
loss of generation efficiency (Section 4.2.2.1.3), there is potential for those
generation losses to impose additional electric system reliability risks.
4.4 Environmental Considerations
Closed-cycle cooling reduces localized fish and shellfish mortality associated with
cooling water intake structure impingement and entrainment, in addition to
reducing the thermal impacts of once-through cooling. However, there are a
variety of potential environmental and social impacts associated with closed-cycle
cooling, the significance of which varies on a site-specific basis. These potential
impacts include effects on terrestrial resources, aquatic resources, public safety
and security, degradation of quality of life and greenhouse gas emissions. EPRIs
Closed-cycle Cooling Research Program included a study of those impacts (Ref.
12). Where possible those impacts were quantified and monetized. The purpose
of this section is to provide a summary of those impacts relative to nuclear
generation stations. There is a significant difference in considering potential
environmental and social impacts for new facilities versus retrofits for existing
facilities. That is, for new generating facilities, those impacts can be considered in
context with the impacts of constructing the entire new generation project, which
allows maximum flexibility to mitigate those impacts in the overall project
design. In the case of closed-cycle cooling retrofits, due to the existing facility
land use and available space, opportunities to mitigate the closed-cycle cooling
impacts may be more limited. The quantified and monetized benefits associated
with those reductions are the topic of Chapter 6.
4-14
4.4.1 Environmental and Social Impacts of Closed-Cycle

Cooling
In general the environmental and social impacts of cooling towers installed at
nuclear facilities have the same issues as those installed at fossil facilities and the
potential impacts to the environment include:
terrestrial wildlife due to noise and habitat loss
terrestrial natural vegetation due to habitat loss and particulate deposition
agricultural crops due to particulate deposition
fish and aquatic life through consumptive water use and the removal of
harmful debris such as plastic material that cause entanglement (an issue for
arid regions).
These can include impacts to rare, threatened or otherwise protected species of

wildlife or vegetation.
Cooling towers also have the potential to pose a risk to public safety as a result of
increased icing and fogging along roadways and nearby airports.
Cooling towers can have social impacts as a result of noise and aesthetics. The
significance of all of these impacts tends to be site-specific and is a function of
the location of the cooling tower on the property and its proximity to:
urban, suburban or residential populations
agriculture land
wetlands
forests
parks
seashores
sensitive habitat for protected species of fish and/or wildlife.
Another important factor relative to potential environmental and social impacts

is the type of waterbody from which cooling water is withdrawn. Facilities
withdrawing from tidal waters have increased levels of salt deposition compared
to those using freshwater. The salt deposition may adversely affect surrounding
vegetation or damage property. Thirteen existing nuclear facilities (one third of
the total), withdraw cooling water from oceans, estuaries or tidal rivers.
The EPRI study on environmental and social impacts was based on a detailed
analysis of 24 representative facilities. Six of the 24 facilities were nuclear
facilities. Following are the areas where there is a significant difference in the
potential impacts between fossil and nuclear facilities:
1. The Overall Level of Impact As discussed in Chapter 3, virtually all nuclear
facilities are baseloaded and have an average generation capacity that is larger
than the average for fossil units. The result is that impacts in the form of
4-15
noise, salt drift, fine particulates, water consumption and visible plumes are
present almost continually, compared to many fossil units that operate less
frequently. Additionally, the overall level of these impacts may be greater,
since these facilities tend to be larger and require larger cooling towers.
2. Greenhouse Gas Emissions Installation of closed-cycle cooling would
increase greenhouse gas emissions by lowering the thermal efficiency of fossil
and nuclear plants and as a result of any fossil generation used to replace lost
nuclear capacity.
A significant advantage of nuclear generation is that no greenhouse gases are
emitted as part of the generation. However, if the baseloaded nuclear facilities
were required to retrofit with closed-cycle cooling, EPRI has estimated that on
average, an extended outage of six months or longer duration may be required.
The result is that the replacement power during these outages would likely be
generated from fossil fuel. EPRIs best estimate of the amount of greenhouse gas
emissions is based on the assumption of an average six month outage; however,
EPRI also estimated emissions assuming an eight month outage. These two
estimates bracket EPAs estimate in the 316(b) Proposed Rule of a seven month
extended outage duration. Assuming a 6-month outage, it is estimated that 163
million tons of CO2 would be generated for all once-through nuclear units, with
74 million tons from facilities on lakes and reservoirs, 67 million tons from
oceans, estuaries and tidal river facilities and 22 million tons from facilities
located on the Great Lakes or small rivers. Assuming an 8-month outage, it is
estimated that 212 million tons of CO2 would be generated for all once-through
nuclear units with 99 million tons from facilities on freshwater lakes, reservoirs or
large rivers, 84 million tons from oceans, estuaries and tidal rivers, and 29 million
tons from facilities located on Great Lakes or small rivers. The estimated
willingness to pay (WTP) to avoid this impact, based on carbon markets using an
average price of $3.80 per ton of CO2 in 2007$, are $13,000,000 and
$16,900,000 for 6- and 8-month outages, respectively. However, the $3.80 price,
while representative of carbon markets at the time of the study, does not
represent the likely price in a world with a national carbon cap or international
carbon agreement to which the U.S. is party.
4-16
Section 5: Water Consumption Rate Data

for Once-Through Cooling
versus Closed-Cycle Cooling
This chapter discusses the water availability issue and the potential for water use
conflicts as consumptive use grows over time. It reviews the relative water
consumption rates for the two primary modes of plant cooling, noting a recent
National Laboratory conclusion that recirculating cooling technologies consume
at least twice as much water as once-through cooling technologies. Actual
consumption data are limited, so this conclusion carries uncertainty. Based on
work by another National Laboratory, this chapter attempts to project the long
term impacts of a significant expansion of closed-cycle cooling, with its higher
consumption rates, on water use in the U.S. These results are regional-specific
and often site-specific. Finally, this Chapter discusses the relationship between
the 316(b) proposed rule and consumptive water use.
5.1 Overview of Issue
Population growth and societal demand for improved quality of life will require
more clean water for drinking and sanitation, more water for irrigation of crops
to feed more people, and expanding supplies of affordable and reliable energy to
meet basic human needs and to enable substantial growth in industry and
commerce. In contrast, the fresh water resources needed for the many aspects of
sustainable development are limited and essentially unexpandable.
The consumptive use of water has major strategic implications to the U.S. and
globally. Water shortages and water use conflicts are already major concerns in
some parts of the U.S. Increased demand by multiple water users (e.g.,
agriculture, municipal water utilities, mining; and water consumption associated
with alternative energy sources such as bio fuels and oil shale) are anticipated,
and shortages are expected to become increasingly acute in coming decades.
Many organizations have concluded that water resources will be affected by many
factors in the future, and this has major impacts on the energy/water nexus.
Following are quotes from recent reports that reinforce the importance and
urgency of water availability as an issue:
5-1
We will run out of water long before we run out of fuel, and the
seriousness of the water crisis will impinge on our lives much earlier
than climate change. (World Economic Forum (WEF) website:
http://www.weforum.org/en/index.htm.) [Ref. 17]
However, as population has increased, demand for energy and water
has grown. Competing demands for water supply are affecting the value
and availability of the resource. Operation of some energy facilities has
been curtailed due to water concerns, and siting and operation of new
energy facilities must take into account the value of water resources.
U.S. efforts to replace imported energy supplies with nonconventional
domestic energy sources [e.g., biofuels, including ethanol and biodiesel;
oil shale, oil sands, etc.] have the potential to further increase demand
for water. (Energy Demands on Water Resources: Report to
Congress on the Interdependency of Energy and Water, DOE, Dec.
2006.) [Ref.18]
Our experiences tell us that environmental stress, due to lack of water,
may lead to conflict, and would be greater in poor nations. (Ban Kimoon, Secretary General of the United Nations, pledging action on
water resources at the World Economic Forum held on 24 January
2008 [see Ref. 17]. He cited a recent report by International Alert
identifying 46 countries, home to 2.7 billion people, where climate
change and water-related crises create a high risk of violent conflict.)
Water is emerging as a significant factor in economic development
activities. Planning efforts must consider the availability and quality of
water resources in a given locality or region to ensure that supplies are
available to accommodate existing and future water consumers over the
long term. Failure to do so can result in stunted growth, economic
flight, inequitable development, and even open conflict. (Estimating
Freshwater Needs to Meet Future Thermoelectric Generation
Requirements, NETL, Sept. 2011) [Ref. 19]
Conflicts between energy production and water availability are on the
rise as the overall pressure on scarce water resources intensifies. Rising
energy costs and concerns about greenhouse gas emissions are forcing
some water managers to seek ways optimize the energy efficiency of
their water systems. Likewise, water scarcity is beginning to affect
energy production, even in areas not traditionally associated with
water-supply constraints. Water-energy conflicts are most acute during
a drought, especially in the summer, when energy demands are high
and water availability is particularly low. (Water for Energy: Future
Water Needs for Electricity in the Intermountain West, Nov. 2011)
[Ref. 20]
Despite these concerns, water and energy policies are rarely integrated.
Federal policies are being developed with little understanding or
concern about the impacts on water resources. In particular, the federal
5-2
government, through subsidies for corn production, has massively

increased the production of ethanol, with little concern for the water
supply and quality implications of this policy. A number of new
trends, including rising electricity demands, the application of carbon
capture and storage technologies, and the pursuit of increasingly
energy-intensive water-supply options, suggest that the conflict
between energy and water resources might intensify in coming years
and pose a serious risk to the future availability and quality of our
nations water and energy resources. In combination, these concerns
and new trends highlight the need to better integrate water and energy
policy. [Ref. 19]
Questions for Congress include who is the most appropriate entity to
respond to energys growing water demand and water vulnerability and
how to respond. At present, little direct federal action is aimed at
managing the energy sectors water demand; instead, the current
division of responsibilities relies on energy interests and state and local
governments to meet and manage energys water demand and resolve
energy-water conflicts. The role of federal policies in contributing to
rising water demand is bringing into question the future federal role in
this policy arena. Local or regional competition for water with existing
users is often what makes energys water demand significant; at the
same time, the regional and local scales of water resources availability
and management complicate many federal water-related actions.
(Energys Water Demand: Trends, Vulnerabilities, and Management,
Congressional Research Service, January 2011) [Ref. 21]
Unfortunately, most nations also suffer from a fragmented approach to
water management. In the United States, more than 20 different
federal agencies have responsibility for various aspects of water policy,
and with a few notable exceptions (the Netherlands and Israel) the
situation is similar elsewhere. Under this fragmented approach,
integrating water policies and management across several sectors is
easier said than done. In many cases, government departments have
policies or regulations that are at odds with each other, such as
environmental regulations that severely restrict the re-use of domestic
waste water. (The Energy Challenge, Nature, March 2008, M
Hightower) [Ref. 22]
Clearly, thermoelectric power plants one of the key users of water are
expected to come under increasing pressure to reduce their consumption of water.
Given that closed-cycle systems, in general, consume at least twice as much water
as once-through systems, it is anticipated there might be increasing instances
where state and regional water authorities in water constrained regions of the
U.S. press for reducing water consumption by the electric power generation
industry.
Increased water consumption rates associated with closed cycle cooling have the
potential to result in increased water impacts in some regions of the U.S.
5-3
Although actual consumption data are currently limited, this chapter attempts to
estimate, based on these limited data, the long term impacts of a significant
expansion of closed-cycle cooling (including new plant trends) on the
consumptive water use in the U.S.
5.2 Relative Water Consumption Rates for Once-Through vs.
5.2.1 NREL Study Conclusions
Even though virtually no water is consumed immediately by once-through
cooling during the cooling process itself, water may evaporate later from the
thermal plume that is created. This is because the warmer discharge water has
an incrementally higher evaporation rate than the cooler source water.
Historically, estimates of these incremental evaporation rates have been difficult
to establish based on plant data, often leading to indirect estimates based on
complex models that consider temperature, humidity, wind speed and other
factors. Water consumption rates from closed-cycle cooling, on the other hand,
can be calculated rather accurately from makeup and blowdown data.
A recent study of water consumption rates for once-through cooling vs. closedcycle cooling has been prepared by the National Renewable Energy Laboratory
(NREL): A Review of Operational Water Consumption and Withdrawal
Factors for Electricity Generating Technologies, March 2011. [Ref. 23]
One important conclusion of this study is that recirculating cooling technologies
consume at least twice as much water as once-through cooling technologies.
Although a very recently issued report, this study relies on decades of data and
prior studies.
The reports methodology was summarized as follows: Data sources include
published academic literature, state and federal government agency reports, nongovernmental organizations reports, and industry submissions to government
agencies for permitting procedures. NREL report[s] minimum,
maximum, and median values for fuel technology and cooling system
combinations in tables and additionally show 25th and 75th percentile data in
figures. Median values for consumptive use of water by nuclear plants were: 672
gal/MWh for closed-cycle cooling, and 269 gal/MWh for once-through cooling.
The NREL study also notes that: Federal datasets on water use in power plants
have numerous gaps and methodological inconsistencies. Federal agencies are
currently coordinating to improve these data. Water use factors discussed here
are good proxies for use in modeling and policy analyses; at least until power
plant level data improve. This coordination follows numerous recommendations
in a recent GAO report [Ref. 24], and is being led by the USGS and the EIA.
Prior studies by EPRI and other national laboratories, going back over two
decades, have consistently indicated that closed-cycle cooling consumes
5-4
significantly more water than does once-through cooling, typically approaching a

factor of two. DOEs Report to Congress: Energy Demands on Water
Resources: A Report to Congress on the Interdependency of Energy and Water,
[Ref. 18] relied on EPRI and national laboratory data. The DOE report listed
nuclear plant water consumption factors at 400 gal/MWh for once-through
cooling and 720 gal/MWh for cooling towers, based on EPRI analysis. These
and other consumption data in the DOE report were based on data from EPRI,
California Energy Commission, NREL, NRDC, and the Pacific Institute.
5.2.2 Empirical Derivation of Once-Through Cooling Water
Consumption Rates
An attempt was made in the preparation of Ref. 4 to determine water
consumption rates for once-through cooling on an empirical basis. The strategy
for doing this was to find data for plants operating on cooling ponds, which in
theory have the ability to determine water consumption rates empirically, using
makeup, blowdown, and rainfall data, similar to how closed-cycle plants can
develop these data. Since makeup to cooling ponds is not continuous (typically
intermittent and/or seasonal), the methodology requires determining a full power
water consumption rate and a zero-power water consumption rate, and
subtracting the latter from the former to determine the amount of water
consumption due to evaporation that results from warmer discharge
temperatures. Obtaining zero power water consumption data is problematic,
unless quality data were obtained during an extended outage at the site (or during
pre-commercial pond operations, if monitored). Data points were obtained from
two plants using the above approach that suggest that once-through cooling
water consumption rates are in the range of 300 gal/MWh. This empirical
approach supports the NREL conclusions above.
5.2.3 Recognition by EPA of Cooling Towers High Water
Consumption Rates
EPAs proposed 316(b) existing facility rule was issued in March 2011,
acknowledging the issue of consumptive use of water.
While wet cooling towers reduce withdrawals relative to once-through
systems, they may increase the consumptive use of water since they
tend to rely on evaporation (which is not returned to the waterbody) for
heat dissipation. When once-through cooling is used and withdrawals
are a significant portion of the waterbody, the return of heated water
may contribute to greater evaporation from the waterbody. However,
EPA does not have data on the relative magnitude of these effects. The
relative loss of water through evaporation for closed-cycle and oncethrough systems is site specific, depending on the exact design of the
systems.11
11
5-5
5.3 How Important is a Factor-of-Two Higher Water

Consumption Rate for Closed-Cycle Cooling vs. Once-Through
Cooling?
5.3.1 NETL Study Conclusions
The DOE National Energy Technology Laboratory (NETL) periodically
publishes a report entitled, Estimating Freshwater Needs to Meet Future
Thermoelectric Generation Requirements. This report was first issued in 2004
and is updated annually. The latest report is dated Sept. 2011 [Ref. 19]. It
contains estimates for five scenarios, with data presented on both a national
average and regional basis. The national and regional data on electricity demand
and capacity forecasts come from the DOEs Energy Information
Administrations (EIAs) Annual Energy Outlook (AEO). The regional
assessment was done in prior years based on 13 North American Electric
Reliability Corporation (NERC) regions, but the most recent update shifted to
the 22 Electricity Market Module (EMM) regions that EIA implemented for
their 2011 AEO. Data are presented for all thermoelectric power plants in the
U.S. (including nuclear), as well as for various breakdowns in fossil technologies.
Nuclear-specific water needs are not broken out explicitly in the report, and EIA
projections tend to be conservative with regard to both nuclear plant license
renewal and new plant construction. Nevertheless, the NETL report is a good
reference for understanding future water needs. NETL estimates future water
requirements (both withdrawal and consumption needs) for five scenarios. These
five scenarios apply to all electric generation: fossil, nuclear, and renewables.
NETL defines their five cases and approach to developing these cases as follows:
Case 1 Additions and requirements are proportional to current water

source and type of cooling system.
Case 2 All additions use freshwater and wet recirculating cooling, while
retirements are proportional to current water source and cooling system.
Case 3 90% of additions use freshwater and wet recirculating cooling, and
10% of additions use saline water and once-through cooling, while
retirements are proportional to current water source and cooling system.
Case 4 25% of additions use dry cooling and 75% of additions use
freshwater and wet recirculating cooling. Retirements are proportional to
current water source and cooling system.
Case 5 Additions use freshwater and wet recirculating cooling, while

retirements are proportional to current water source and cooling system. Five
percent of existing freshwater once-through cooling capacity is retrofitted
with wet recirculating cooling every five years starting in 2015.
Future water withdrawal and consumption for the U.S. thermoelectric
generation sector are estimated for five cases one reflecting status quo
conditions, two reflecting varying levels of regulations regarding
5-6
cooling water source, one incorporating dry cooling, and one reflecting
regulatory pressures to convert existing once-through capacity to
recirculating capacity.
The five cases were selected to cover the range of possible design
choices for new power plants including the source of water (fresh or
saline) and type of cooling system (wet recirculating or dry). In
addition, Case 5 assumes that 25% of existing power plants with a
once-through cooling system are retrofit with a wet recirculating
system. For all five cases, it is assumed that plant retirements occur
proportional to current water source and cooling system type.
Since a primary goal of this chapter is to estimate the impacts of potential

widespread expansion of closed-cycle cooling on the consumptive use of water in
the U.S., it is necessary to estimate which of the above five cases represents the
most likely future rate of conversion from once-through cooling to closed-cycle
cooling in the U.S. It is important to note that the proposed EPA rule conducted
extensive analysis of the cost impacts of such conversions under its three options,
as discussed previously in Chapter 2. EPA also examined the impacts of its three
options on other important considerations, including impacts on grid reliability,
plant closures, and capacity losses. However, EPA did not analyze the impacts of
its proposed options on the consumptive use of water. Similarly, EPRI has not
conducted a detailed study of this question to date but did address the question
generally in Ref 11, as discussed in Section 5.3.2 below. This chapter therefore
refers primarily to studies conducted by NREL and NETL. It also points to the
need for more detailed study of water consumption impacts on a watershed or
regional basis.
Of these five cases above, Cases 2 and 5 are the most relevant to nuclear plants,
for reasons discussed below for each case. NETL defines the rationale for these
two cases as follows:
Case 2 represents a regulatory-driven situation under which NETL assumed that
316(b) and future regulations dictate the use of recirculating systems for all new
capacity. Retirement decisions hinge on age and operational costs, rather than
water source and type of cooling system. Under this case, EPAs Phase I
requirements remain in effect for new plants, but current plant requirements
revert back to the EPAs 2004 Phase II rule, which allowed for substantial sitespecific flexibility in making once-through cooling vs. closed-cycle cooling
decisions. Note that while the 2004 Phase II rule allowed for flexibility, there was
nothing in that Rule to prevent the permitting authority from requiring a retrofit
to closed-cycle cooling. Thus, Case 2 represents a situation where few currently
operating facilities would be required by their permitting authority to convert to
Case 5 (the conversion case) is the same as Case 2, except regulatory and public
pressures compel state agencies to dictate the conversion of a significant amount
of existing freshwater once-through cooling systems to wet recirculating.
Although there is no direct connection between NETLs conversion assumption
5-7
for Case 5 (5% of existing fresh water once-through cooling capacity being
retrofitted with wet recirculating cooling every 5 years starting in 2015, for a total
of 25% conversion) to any assumption or requirement in the proposed EPA rule,
this scenario represents a reasonable point of departure for estimating the impacts
of wide-spread conversion of the existing fossil and nuclear fleets. As discussed
later, this 25% conversion rate could represent either an under-estimate or overestimate of the actual impacts of the draft rule, in combination with a rate of
conversions driven by permitting authorities or other factors not linked directly to
required responses to the draft rule (i.e., unilateral NPDES actions).
Case 1 is defined by NETL as the Status Quo scenario case. It assumes that
additions and retirements follow current trends. It represents a roll-back of Phase
I rulemaking requirements for new plants such that current ratios of oncethrough vs. closed-cycle cooling remain in effect, and assumes no significant
retrofitting of existing once-through facilities.
Case 3 is defined by NETL as the Regulatory-light case. New additions favor
the use of freshwater recirculating systems, but some saline capacity using oncethrough cooling is permitted. Retirement decisions remain tied to age and
operational costs, tracking current source withdrawals, which effectively assumes
no significant retrofitting of existing once-through facilities.
Case 4 is defined by NETL as the Dry cooling case. Regulatory and public
pressures result in significant market penetration of dry cooling technology.
Retirement decisions remain tied to age and operational costs, tracking current
source withdrawals. As discussed in Chapter 2, this option is not feasible for
nuclear plants, and was acknowledged as such by EPA in the proposed rule.
National Average Results: Because of the trend away from once-through cooling
in all cases except Case 1, water withdrawal rates decline in Cases 2-5. As
expected, water consumption rates increase in all five cases, with Case 5
providing the largest water consumption impacts. These results are driven by
regulations and industry practice [in response to these regulations] which favor
the use of fresh water recirculating cooling systems that have lower withdrawal
requirements but higher consumption requirements than once-through cooling
systems. For Case 5, the percent of total U.S. water consumption attributable to
thermoelectric power plants rises by 28.4% by 2035.
Regional Results: The impacts on water consumption rates for these five cases
are more dramatic when analyzed on a regional basis, with the greatest impacts
evident in regions with high projected population growth and freshwater supply
limitations. Table 5-1 highlights the EMM regions with the highest projected
impacts on water consumption rates, focused on NETLs Case 2 and Case 5
scenarios.
5-8
Table 5-1
Selected Regional Water Consumption Data from NETL Report (Ref. 19)
% increase in Water
Consumption, 20102035
EMM
Region
3-MROE
Case 2
Case 5
Impacted States (smaller portions of

states in parentheses are included in
the region)
57
117
Wisconsin, (Michigan)
124
124
New Yorks Long Island
15-SRCE
35
86
Kentucky, Tennessee, (Alabama)
11-RFCW
17
55
Indiana, Ohio, West Virginia, (Virginia),

(Pennsylvania), (Illinois), (Michigan),
(Kentucky), (Maryland)
13-SRGW
65
Missouri, Illinois
14-SRSE
26
31
Alabama, Georgia, (Mississippi), (Florida)
16-SRVC
14
40
North Carolina, South Carolina, Virginia
1-ERCT
19
31
Texas
4-MROW
12
30
North Dakota, South Dakota, Nebraska,

Iowa, Minnesota, (Montana), (Wisconsin)
5-NEWE
28
36
Maine, New Hampshire, Vermont,

Massachusetts, Rhode Island, Connecticut
8-NYUP
12
45
New York
10-RFCM
16
35
Michigan
7-NYLI
How significant are these projected increases in water consumption? There is no

overall answer to this question, since impacts will be regional-specific and often
waterbody specific. For regions with ample year-round water resources and for
thermoelectric generation cooled by ocean water, these consumptive impacts are
not likely to be consequential. However, for water-stressed regions, and for water
bodies that are susceptible to low flow or lowering water levels or drought during
hot summer months, these increased consumption rates could create water use
conflicts with other water users. More regional-specific or even site-specific
studies are needed.
Note: the NETL report contains much more detail than presented here,
including data for both withdrawal and consumption for all regions and all cases,
with a breakdown for various fossil technologies.
Below is a U.S. map that displays the EMM regions developed by EIA. The map
can be obtained from either Ref. 19 or the EIA website.
5-9
Figure 5-1
2010 Thermoelectric Water Consumption by EMM Region (Ref. 19)
5.3.2 EPRI Study Conclusions

EPRIs report, Net Environmental and Social Effects of Retrofitting Power
Plants with Once-through Cooling to Closed-cycle Cooling [Ref. 12] addresses
evaporative water loss as one of the impacts of retrofitting. In summary:
Conversion to a closed-cycle cooling system will increase the
evaporation rate compared to a once-through cooling system.
Consumptive water loss from proposed closed-cycle cooling towers at
modeled facilities is between ~400-900 gallons per megawatt (MW)hr. electricity generation for fossil-fueled facilities and approximately
750-1,050 gallons per MW-hr. for nuclear facilities, which is over
double the water loss estimated for once-through cooling Nationally,
the total estimated freshwater evaporative loss is estimated to be 500
billion gallons/yr. (372 billion gallons/yr. for facilities on large rivers,
reservoirs and lakes other than the Great Lakes and 128 billion
gallons/yr. for facilities on the Great Lakes and small rivers). Note that
permitting and/or the issue of obtaining additional water rights to
maintain water levels for cooling lakes and ponds in southwestern arid
portions of the United States such as Texas and Oklahoma are not
evaluated in the study.
5-10
The methodology for quantifying the effects of retrofitting relied on plant

specific analyses of five Beta Test Plants (BTPs) and four Reference Facilities
(RFs) used throughout the EPRI report series. Two of these nine plants were
nuclear plants. For these two plants, the estimated annual average in-stream
evaporation rates were 9,600 gpm and 13,100 gpm (averaging to 11,350 gpm). In
general, the difference in evaporation between once-through cooling and closedcycle cooling is greater in lower wet-bulb locations (i.e., in the western half of the
U.S. and the northern U.S.). Therefore, retrofitting once-through facilities with
cooling towers could increase consumptive loss of water in already drier locations.
From Ref. 12:
The evaporative loss due to the installation of mechanical-draft
evaporative cooling towers may result in reductions in the availability of
potable water, a decrease in water surface elevation on rivers and lakes
and corresponding loss of aquatic and riparian habitats and recreational
uses, and a decrease in the assimilative capacity of the river. The
magnitude of these possible impacts would correspond to the percent of
the water loss relative to the in-flow. Note that evaporative loss from
plants located on large waterbodies is less likely to be a significant
issue.
Additional evaporative loss from mechanical-draft evaporative cooling
towers may be exacerbated during drought conditions. The declaration
of drought conditions by a state or regional water resources authority is
driven by regional or local stream flows or water surface elevations. The
increase in consumptive water use resulting from cooling towers may
increase the frequency of drought declarations in the watersheds of the
source waterbodies.
On an individual plant basis, the effects of evaporative loss to total flow rates and
water levels in the source waterbody were minimal. WTP monetization was
based on potential changes in water levels to the extent that recreational activities
(boating, fishing, etc.) would be impacted. However, the methodology did not
evaluate the impacts of evaporative loss on the competition among water users
(e.g., municipal water supplies, agricultural use); nor did it evaluate the
cumulative effects of multiple retrofitting or new plant construction on a regional
basis. One additional economic impact on plants in dry regions is the cost of
water rights. Many power companies own or buy water rights for their facilities.
These water rights can be substantial and could approach the cost of building and
operating a cooling tower. These costs, which can range up to $7,500 per acrefoot, would need to be accounted for in a cost-benefit analysis.
EPRIs report, Water Use for Electricity Generation and other Sectors: Recent
Changes (1985-2005) and Future Projections (2005-2030), EPRI Report
1023676; [Ref. 25] provides additional insights for water usage trends. This
report focuses on water withdrawal, available water resources and forecasts future
trends relative to those resources, thus providing helpful context for water
consumption that is more the focus of this report. This study documents that
5-11
water in some regions of the U.S. is already in short supply and is forecasted to
get worse to 2020. One of the conclusions from this report states:
Future projections of water withdrawal and water availability were
composited into an index that compared, on a relative basis, the water
supply sustainability risks through the U.S. Metrics considered in the
index include the extent of water development already in place,
dependence on groundwater, the regions susceptibility to drought,
projected increases in water use, and the difference between peak
summer demand and available precipitation (a measure of storage
requirements). The water supply sustainability risk index shows that the
most significant future water stresses are in the Southern/Southwestern
U.S., and in the Great Plains states. When the locations of existing
power generation facilities are overlaid on the map of the index,
roughly 250,000 MW of generation, or about a quarter of the U.S.
total, are in counties that are associated with some type of water
sustainability concern. It is likely that no matter what future water
withdrawals are, water sustainability constraints will emerge not during
average flow years, but during years of below-normal precipitation.
However, pressure for supplies during average rainfall years is a strong
indicator of the potential of sustainability risk when rainfall is below
average.
The report also points out that improved efficiency in water use and conservation
will be important areas of focus to ensure adequate future water supply.
5.4 Discussion
The following discussion relates the above review of consumptive water use to
the proposed 316(b) rule, and specifically to how a conclusion that closed-cycle
cooling technologies are estimated to consume twice as much water as oncethrough cooling might impact various scenarios under that rule.
In terms of 316(b), it is currently unclear how many facilities will be required to
retrofit under EPAs Proposed Rule. Important considerations relative to 316(b)
as a potential driver of closed-cycle cooling retrofits and the resulting increase in
consumptive water use include:
The BTA decision on entrainment specifically requires evaluation of closedcycle cooling for facilities that use more than 125 MGD actual flow, which
would include all nuclear facilities. The permitting authorities BTA decision
on closed-cycle cooling will be based on consideration of the cost, benefits,
potential reliability impacts and environmental impacts. It is anticipated that
some retrofits may be required.
While the impingement mortality reduction requirements are not based on

closed-cycle cooling as BTA, it is unclear whether or not closed-cycle cooling
retrofits could be required, if a facility could not comply with the biological
compliance monitoring criteria to limit impingement mortality to 12%
annually and 31% monthly and could not reduce the maximum through
5-12
screen design velocity to not exceed 0.5 fps. Thus, some plants may be forced
to consider retrofitting closed-cycle cooling as the only means of complying
with impingement requirements.
Additionally, some state or EPA Regional NPDES permitting authorities have
already initiated processes to require existing thermoelectric facilities to install
closed-cycle cooling (New York, California, Delaware, and New England).
Although these states have taken this action on their own, these decisions may
result in increased consumptive use of water in the impacted states. Also note
that the proposed rule includes an implicit encouragement for other permitting
authorities to follow suit: EPA supports these state efforts and determinations
and thinks that similar decisions would be able to be made under this proposed
rule. (at 76 Fed. Reg. 22210)
EPA could select Options 2 or 3 (both based on close-cycle cooling as BTA), in
which case the impacts on consumptive water use could be much greater than any
of the cases analyzed by NETL. Options 2 or 3 would result in a consumption
rate increase of roughly 100% on a national average basis and regional increases
ranging from 120% to over 400% for the EMM regions identified in the table
above.12 The potential costs, financial, reliability and environmental impacts of
Options 2 or 3 are estimated in EPRIs Closed-cycle Cooling Retrofit Research
Program, and were summarized in Chapter 4.
As discussed in Chapter 2, proposed changes to the existing facilities 316(b) rule
carefully evaluated a wide range of societal impacts that would result from the
four options considered, including impacts on grid reliability, plant closures,
capacity losses, etc. However, EPA did not evaluate the impacts of designating
closed-cycle cooling as BTA (i.e., Options 2 and 3) on consumptive water use
and the resulting issues associated competing water needs from different
stakeholders.
The result of the combined concerns over water availability, thermal issues and
CWIS impacts as drivers for use of closed-cycle cooling for new and existing
facilities has potentially significant implications for future consumptive water use.
Failure to consider these implications may adversely affect future water use in
some regions of the U.S.
These estimates are based on multiplying the Case 5 results by four. Case 5 assumes an eventual
conversion rate of 25% of existing facilities to closed-cycle cooling, so 4 X 25% approximates the
impacts of 100% conversion.
12
5-13
Section 6: Impacts of Once-Through

Cooling to Fish and Aquatic
Life
This Chapter provides information on the level of adverse impacts, or conversely
the benefits of addressing them, so that they can be compared to the cost and
environmental and social impacts of retrofitting the 39 once-through cooled
nuclear power plants with closed-cycle cooling. Thermal and cooling water intake
structure impacts are discussed.
6.1 Thermal Discharge
As discussed in Section 2.4.1, heat is unique as a pollutant, in that it is physical
rather than chemical in nature and is temporary rather than persistent once it is
introduced into the water. A number of facilities, including some nuclear power
plants, are unable to meet the thermal water quality criterion for heat in their
receiving waterbody, and have sought 316(a) thermal variances. The result is that
a significant body of work on the effects of thermal discharges on fish and other
aquatic life has been generated and reported in 316(a) Demonstration Reports
submitted to request alternate thermal effluent limitations. The majority of the
facilities were successful in obtaining thermal variances. However one nuclear
facility, the Palisades Power Plant in Michigan, was required to retrofit to closedcycle cooling to address thermal concerns.
Two-thirds of the 39 nuclear facilities using once-through cooling have an
approved site-specific 316(a) variance that will assure the protection and
propagation of a balanced, indigenous population of shellfish, fish, and wildlife in
and on that body of water. The other one-third of these facilities meets the
thermal discharge criteria set by the permitting authority for facilities within their
jurisdiction, and do not need a site-specific variance.
6.2 Cooling Water Intake Structures
This Section provides an overview of current levels of impingement and
entrainment resulting from nuclear power plants (6.2.1) and the impacts from
those losses to the source waterbody (6.2.2).
6-1
6.2.1 Current Level of Impingement and Entrainment at

Nuclear Facilities
EPRI created a database from impingement and entrainment studies conducted
for compliance with the now remanded Phase II Rule. Companies submitted a
summary of their impingement and entrainment data along with information on
the facility, the study methods, the method used to estimate annual impingement
and entrainment as well as other parameters. Impingement data for 166 facilities
and entrainment data for 90 facilities were provided. Under the Phase II Rule,
facilities that withdrew cooling water from a river and used less than 5% of the
mean annual flow and those located on freshwater lakes, other than the Great
Lakes, or reservoirs were not required to conduct entrainment characterization
studies. Facilities were asked to estimate the total annual impingement and
entrainment losses based on actual cooling water flow. They were also asked to
input annual estimates of impingement and entrainment for the top 10 species of
fish and shellfish impinged and entrained. A complete description of the study
methods and findings is provided in EPRI Technical Report 1019861 [Ref. 14].
Seventeen (or 44%) of the 39 nuclear facilities provided a summary of their
impingement data and eight (or 25%) provided a summary of their entrainment
data. Direct comparisons between facility loss numbers were not made, since to
be meaningful, such comparisons require converting entrainable life stages into
equivalent age 1 or equivalent adult organisms. That was a subject of EPRI
Technical Report 1023401 [Ref. 13], and is discussed below in Section 6.2.2.
6.2.2 Impacts on the Source Waterbody
The CWA 316(b) statutory language requires facilities to minimize adverse
environmental impact (AEI). However, what constitutes AEI has never been
defined and has been the subject of extensive debate. Some argue that one dead
fish is an AEI, while others consider it a population level impact that poses a
threat to the populations sustainability. It is a subject that EPRI has studied
from a technical standpoint. A summary of that information is provided in
Sections 6.2.2.1 through 6.2.2.4.
In July 2011 EPRI completed technical report 1023094 titled Do Power Plant
Impingement and Entrainment Cause Adverse Changes in Fish Populations? A
Review of the Scientific Evidence. [Ref. 26] The approach focused on six sources
of information that included:
1. Peer-reviewed literature from studies on impingement and entrainment
impacts from power plants on fish populations
2. Peer-reviewed technical papers in the scientific literature linking
impingement and entrainment to reductions in freshwater or marine
ecosystem services
3. Papers in the scientific literature linking impingement and entrainment to
reductions in freshwater or marine ecosystem services
6-2
4. Blue-ribbon commission reports such as the Pew Ocean Commission

report and relevant National Academy of Sciences Reports that discuss
causes of fish population decline and marine ecosystem degradation
5. EPAs reports on the condition and causes of degradation of coastal
ecosystems
6. Peer-reviewed papers and agency stock assessment reports documenting the
causes of declines in marine and freshwater fish populations.
While the literature survey did not specifically focus on nuclear facilities, they
were included in the scope of this project. A number of sources were identified
including Pew Oceans Commission and National Research Council Blue Ribbon
Panels and EPA National Research Council documents. Significant issues cited
as threats to coastal fisheries included overfishing, habitat alternation, nutrient
enrichment, invasive species and non-point source pollution. However, impacts
from cooling water intake structures were never mentioned as a threat to
fisheries. Sixteen studies were found with specific reference to cooling water
intake structures. Three of those were retrospective studies that found no
impacts. Seven of the studies were modeling studies, four finding no impact and
three finding a potential for impact. Four studies focused on equivalent adult
losses from impingement and entrainment and all four found those losses were
negligibly small compared to fishery harvests. Two of the studies focused on
cumulative impacts; and both were found to be inconclusive, with one concluding
that it was currently not possible to develop a reliable cumulative impacts
estimate because the requisite data to perform the assessment were not available.
The Supreme Court decision on whether or not the EPA could consider cost
relative to benefits in making the BTA determination was issued in April 2009.
That decision determined that EPA could consider the benefits in context with
the costs to establish the BTA standard and EPRI initiated research to estimate
the national benefit to commercial and recreational fisheries of closed-cycle
cooling as BTA for existing facilities. The results of that research were entered
into the public record during the 316(b) existing facilities comment period in
EPRI Technical Report 1023401 [Ref. 13]. EPRIs approach involved use of its
impingement and entrainment database and a number of site-specific 316(b)
benefit valuation studies. Specifically, EPRI acquired 70 impingement and/or
entrainment site-specific benefit valuation estimates and generated another 34
impingement and entrainment mortality reduction estimates. The methods used
to estimate the benefit assumed a 95% reduction in impingement and
entrainment would be achieved. The biological and economic assumptions were
based on methods very similar to those used by the EPA to estimate the benefits
of the Phase II Rule and proposed Existing Facility Rule.
The methods for converting the facility-level estimates into the national benefit
estimates used EPRIs list of 428 Phase II facilities (including the 39 nuclear
facilities) and allocated those facilities into three tiers based on the information
available for the facility. Tier 1 facilities were estimated with the site-specific
benefit estimates that were either acquired or generated by EPRI. Facilities in
Tier 2 had current (i.e. collected for compliance with Phase II Rule) quantitative
6-3
impingement and/or entrainment sampling data results. EPRI found there was
an acceptable correlation between the numbers of organisms impinged and/or
entrained in the database and the site-specific economic benefit estimates. Thus
Tier 2 estimates were made for all facilities in the EPRI Phase II Facility
Database for which no site-specific impingement and entrainment mortality
reduction benefit had been generated. Tier 2 consisted of 127 facilities with
impingement data and the 45 facilities with entrainment data. For the remaining
facilities (196 facilities for impingement and 313 facilities for entrainment) that
were not in the EPRI database and had no site-specific benefit estimates, the
benefit estimate was based on a statistical model of the relationship between
plant design flow and the acquired or generated site-specific benefit estimates.
Thus, the national benefit estimate is the sum of the existing benefit valuation
studies, the site-specific benefit valuation studies, the estimated benefits for
facilities with I&E data, and the estimated benefits for facilities without
impingement and entrainment data.
This total estimated national annual benefit was $16 million from retrofitting all
existing Phase II facilities with closed-cycle cooling. This estimate includes the
economic benefit to commercial fisheries based on the expected increase in
commercial harvests and the increased willingness to pay by recreational
fishermen due to their expected increased catch per fishing trip. The national
benefit from retrofitting the 39 nuclear once-through cooled facilities was
estimated to be $2.9 million/yr. or just under 18% of the total annual
impingement and entrainment mortality reduction benefit estimate. Based on the
annualized cost to retrofit the nuclear facilities with closed-cycle cooling of $2.28
billion/yr. (includes capital cost, lost revenue due to an extended outage, energy
penalty and heat rate penalty), the annualized cost is 792 times greater than the
annual benefit. The benefit estimate was based on the commercial and
recreational fishing benefit and did not include non-use benefits. However, this
comparison also excludes the monetized economic costs associated with the
environmental and social impacts of closed-cycle cooling discussed in section
4.4.1.
6.3 Insights from NRC Environmental Reviews
The following summary of the Nuclear Regulatory Commissions (NRCs)
environmental review process and results relative to cooling water issues is taken
from Ref. 4. The text has been updated and shortened, with less detail on the
NRC licensing processes, particularly related to new plant licensing, and
omission of site-specific details. See Ref. 4 for a more complete discussion.
6.3.1 NRCs Environmental Review Process
As part of its responsibility to license nuclear facilities in the U.S., the NRC has a
role in assessing environmental protection issues. NRCs authority and obligation
under federal law to assess the environmental impacts of its decisions comes from
the National Environmental Policy Act (NEPA), which specifies that a major
Federal action significantly affecting the quality of the human environment
requires a detailed statement on, among other things, the environmental impact
6-4
of the proposed action and alternatives to the proposed action. The statement is
to accompany the proposal through the agency review process. The Act also
established in the Executive Office of the President a Council on Environmental
Quality, which has issued regulations on the preparation of environmental impact
statements and on public participation in the preparation of the statements.
NRC has determined that the license renewal of an existing nuclear reactor and
the licensing of a new nuclear reactor both constitute major Federal actions.
This in turn invokes the processes described below, quoted or paraphrased from
the NRC website sections on Reactor License Renewal and New Reactors.
License Renewal: The NRC has established a timely license renewal process
and requirements, codified in 10 CFR Part 51 [Environmental Protection
Regulations for Domestic Licensing and Related Regulatory Functions] and 10
CFR Part 54 [Requirements for Renewal of Operating Licenses for Nuclear
Power Plants], that are needed to assure safe plant operation for extended plant
life. The timely renewal of licenses for an additional 20 years, where appropriate
to renew them, may be important to ensuring an adequate energy supply for the
United States during the first half of the 21st century.
New Reactors: For new reactor facilities, the NRC reviews applications
submitted by prospective licensees, and (when appropriate) issues standard design
certifications, early site permits, limited work authorizations, construction
permits, operating licenses, and combined licenses. Of the NRC's existing
regulations, the following are most relevant to the design, siting, construction,
and operation of new commercial nuclear power facilities:
10 CFR Part 51, "Environmental Protection Regulations for Domestic

Licensing and Related Regulatory Functions"
10 CFR Part 52, "Licenses, Certifications, and Approvals for Nuclear Power
Plants
Under the NRC's regulations in 10 CFR Part 52 and in

accordance with the applicable provisions of 10 CFR Part
51, which are the NRC regulations implementing the
National Environmental Policy Act (NEPA), the NRC is
required to prepare an environmental impact statement
(EIS) as part of its review of an early site permit (ESP) or
combined license (COL) application. The NRC staff
currently conducts its environmental reviews using
NUREG-1555, "Environmental Standard Review Plan"
(ESRP).
6.3.2 NRC Review and Approval of Nuclear Plant Cooling
Water Systems:
Based on the above requirements that major Federal actions such as initial
licensing or re-licensing of a nuclear plant be reviewed to ensure conformance to
the National Environmental Policy Act, the NRC reviews the cooling water
systems of all nuclear plants for conformance to Federal environmental
6-5
requirements, including EPA requirements, in addition to its own nuclear safety

requirements. These safety and environmental reviews are done in parallel; and
NRC authorization for initial operation (or continued operation during a license
renewal period) is granted only after both safety and environmental requirements
are met.
In the case of license renewal, an applicant must submit a detailed application
under Part 54 for the plants design and operation, and a separate application
under Part 51 for its compliance with NEPA. In the case of new plants, the
applicant has options. Part 52 was designed for the baseline case in which an
applicant applies for an Early Site Permit (ESP) without a commitment to a
particular design or construction plan. Separately, standardized reactor designs
are submitted by reactor vendors for safety review and approval by NRC via a
rulemaking process (Design Certification or DC). An owner-operator, would
then take the approved site (previously approved by NRC using the Part 52 ESP
process) and a certified reactor design, and merge them into an integrated
application to construct and operate that design on that site (the Combined
License, or COL). However, Part 52 gives the applicant the flexibility to
combine these steps in various ways or to pursue them in parallel instead of in
series, albeit with some increased regulatory risk. In all cases, the environmental
reviews are included in either the ESP or the COL process. Also, the ESP and
DC reviews and approvals, including public hearing and comment periods
prescribed by law, must be completed before the COL is issued.
For both new plant and license renewal reviews, the NRC provides generic
guidance to applicants on the required content of their site specific
Environmental Reports, primarily via NUREG-1555 (Standard Review Plan)
and NUREG-1555, Supplement 1: Operating License Renewal, respectively,
and supporting Regulatory Guides. In addition, NRC conducted a formal
generic evaluation of environmental issues relevant to License Renewal, to
narrow the scope of information that needs to be provided. This generic
evaluation, NUREG-1437, Generic Environmental Impact Statement for
License Renewal of Nuclear Plants (GEIS) was issued in 1996. The NRC then
issues a site-specific Supplement to this GEIS (the EIS) to report its findings
and conclusions on each Environmental Review.
Under the GEIS process, the NRC staff identified 92 environmental issues and
reached generic conclusions related to environmental impacts for 69 of these
issues that apply to all plants or to plants with specific design or site
characteristics. Additional plant-specific review is required for the remaining 23
issues. These plant-specific reviews are to be included in a supplement to the
GEIS.
The GEIS evaluated all 92 environmental issues using the NRCs three-level
standard of significancesmall, moderate, or largedeveloped using the
Council on Environmental Quality guidelines:
SmallEnvironmental effects are not detectable or are so minor that they

will neither destabilize nor noticeably alter any important attribute of the
resource.
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ModerateEnvironmental effects are sufficient to alter noticeably, but not

to destabilize, important attributes of the resource.
LargeEnvironmental effects are clearly noticeable and are sufficient to

destabilize important attributes of the resource.
For 69 of the 92 issues considered in the GEIS, the GEIS analysis reached the
following conclusions:
1. The environmental impacts associated with the issue have been determined
to apply either to all plants or, for some issues, to plants having a specific type
of cooling system or other specified plant or site characteristics.
2. A single significance level (i.e., small, moderate, or large) has been assigned
to the impacts (except for collective offsite radiological impacts from the fuel
cycle and from high-level waste and spent fuel disposal).
3. Mitigation of adverse impacts associated with the issue has been considered
in the analysis, and it has been determined that additional plant-specific
mitigation measures are not likely to be sufficiently beneficial to warrant
implementation.
These 69 issues were identified in the GEIS as Category 1 issues. In the absence
of new and significant information, the NRC staff relied on conclusions in the
GEIS for issues in Category 1.
Of the 23 issues that do not meet the criteria set forth above, 21 are classified as
Category 2 issues requiring analysis in a plant-specific supplement to the GEIS.
The remaining two issues, environmental justice and chronic effects of
electromagnetic fields, were not categorized.
Of the 92 issues, 40 relate or could relate to water issues in four broad categories:
Surface Water Quality, Hydrology, and Use (for all plants)
Aquatic Ecology (for plants with once-through and cooling pond heat
dissipation systems)
Ground-water Use and Quality
Threatened or Endangered Species (for all plants).
Of the 40 issues potentially related to water, ten have been determined to

potentially involve moderate or large environmental impacts at some sites and
thus require site-specific evaluation. Those ten issues include impingement,
entrainment, heat shock, ground water impacts, threatened or endangered species
considerations, etc.
6.3.3 Current Status and Findings
As of the publication date of this report, 71 individual reactor units have been
reviewed and approved for license renewal. Another 15 reactors are under review,
at various stages of completion. Of these 15, six have proceeded far enough in the
review process to have received from NRC their EIS or Draft EIS for public
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comment. Therefore, 77 reactors (74% of the U.S. fleet) have either completed
environmental review or are sufficiently complete to have received an initial
assessment from NRC with regard to findings on the ten water-related issues.
Of these 77, all but 12 plants at nine sites have been determined to have small
environmental impacts. Of the 65 reactors that have been judged to have small
environmental impacts, 51 use once-through cooling.
The remaining 12 reactors were found to create moderate (or small to moderate)
environmental impacts, primarily in one or more of the ten site-specific waterrelated categories. The areas of concern for most of these plants were in one or
more of the Aquatic Ecology issues, most frequently impingement or
entrainment.
All of the reactors with moderate impingement and entrainment issues are in an
ocean, estuary, or tidal river (O/E/TR) environment. However, it is important to
note that not all reactors in O/E/TR environments have issues with
impingement and entrainment: Thirteen reactors at O/E/TR sites have been
judged to have small environmental impacts. Twelve of these 13 reactors use
once-through cooling on O/E/TR sites. In summary, NRC has determined,
based on NEPA criteria, that over 60% of reactors on O/E/TR sites that have
been evaluated to date for license renewal exhibit small environmental impacts.
6.3.4 Discussion
A finding of moderate on a few issues has not been disqualifying for license
renewal, which assesses the overall environmental impacts in all areas against
alternatives, as well as all the reactor safety issues (issues related to aging of plant
structures, systems and components, etc.) A number of plants have successfully
renewed their operating licenses with one or two issues judged as presenting
moderate impacts.
Each of these environmental reviews is conducted in consultation with Federal,
state and local agencies, including EPA and state water permitting authorities.
NRCs environmental review is based on NEPA regulations and its GEIS, as
discussed above. NRCs application of NEPA is in accordance with NEPA and
CEQs implementing regulations, and allows for consideration of the impacts on
the source waterbody as a whole. Even though acceptance criteria differ among
these agencies, the findings and recommendations of the NRC do reflect the
input of EPA and state authorities.
The NRCs interpretation of NEPA requires the staff to assess the
environmental impacts of cooling water issues on the overall environment in a
holistic manner. This means the NRC strives to assess AEI on the source
waterbody, as opposed to inferring AEI based on extrapolating entrainment and
impingement data. This approach can be more difficult or subjective in terms of
data collection and interpretation, but may provide an indication of true impacts
on the ecosystem.
6-8
The NRCs approach is very site-specific. The generic portion of its Part 51
process is applied only to help eliminate environmental issues that are not
applicable or that can be easily demonstrated to be of no concern. Any
environmental issue of potential significance is fully assessed on a site-specific
basis. Stakeholder inputs to NRC are strongly site-specific.
The NRC does not employ rigid acceptance criteria. Rather, it utilizes the
rankings provided under NEPA for small, medium, and large impacts, and
assesses the adequacy of environmental protection accordingly.
The owner/operator must demonstrate acceptable environmental performance. If
the NRC determines that performance is inadequate, it is the responsibility of
the owner/operator to propose alternate technologies or actions to mitigate the
AEI. The owner/operator can consider costs and benefits in proposing its
approach to address AEI.
6-9
Section 7: Use of Alternative Fish

Protection Technologies as BTA
for Nuclear Facilities
The purpose of this Chapter is to summarize currently available fish protection
technologies and operational measures that have the potential to reduce
impingement and/or entrainment. It is generally the case that any entrainment
reduction technology will also reduce impingement. A summary of the existing
use of alternative fish protection technologies and operational measures at nuclear
power plants is provided, followed by an overview of technologies that could
reduce impingement mortality and entrainment mortality. Each of the fish
protection technologies discussed can vary significantly in terms of performance,
practicality and cost on a site specific basis. EPRIs report on fish protection at
cooling water intakes [Ref. 27] provides a much more detailed discussion of the
alternative fish protection technologies and operational measures.
Over the last two to three decades, the power industry has developed a wide
range of technology options that are proving to be highly effective in reducing
CWIS impingement and entrainment, particularly in the impingement category.
Many of these technology options were not available or adequately developed
back in the 1980s when cooling towers became more prevalent. For impingement
mortality reduction, these technologies often provide equivalent aquatic life
protection performance to cooling towers, depending on site-specific and speciesspecific factors. For entrainable life stages, the available technologies are more
limited. However, relatively good performance can be achieved depending on
site-specific factors and the life stage of the organisms vulnerable to entrainment.
7.1 Existing Use of Fish Protection Measures at Nuclear
Facilities
Nearly a third of the 39 once-through cooled nuclear power plant sites currently
employ either some form of impingement and/or entrainment reduction
technology and/or have instituted environmental mitigation measures to offset
impingement and entrainment losses. The list of these facilities and a summary
of the fish protection actions is as follows:
7-1
1. Brunswick Nuclear Plant Brunswick uses a combination of a fish diversion

structure at the entrance to the intake canal combined with modified
traveling screens to reduce impingement mortality by >90%.
2. Crystal River The Crystal River complex incorporates four fossil units and
one nuclear unit. Fossil Units 1&2 and nuclear Unit 3 are once-through
cooled; fossil Units 4&5 are closed cycle-cooled. Florida Power Corp.
opened the Crystal River Mariculture Center in 1991, a multi-species marine
hatchery intended to mitigate impacts of the Crystal River plants oncethrough cooling system. The Mariculture Center includes an 8,100 square
foot hatchery building with four spawn rooms and eight one-acre grow-out
ponds. (Note 1)
3. D.C. Cook Nuclear Plant This facility has installed a high frequency
acoustic deterrent system to reduce impingement of alewife, a dominant
impingement species. D.C. Cook has evaluated the benefits of installing an
off-shore intake. Under the Phase II Rules calculation baseline, D.C. Cook
would have reduced impingement mortality by 98% and entrainment
mortality by 86% as a result of locating the intake off shore rather than at the
shoreline.
4. Indian Point Indian Point Units 2&3 use modified vertical Ristroph
traveling screens. Key fish-protection components are screen basket lip
troughs designed to retain water and minimize vortex stress, a low-pressure
spray wash system for fish removal from the rear side of the machine, and a
fish sluice system for collection of the impinged fish for return to the river.
Indian Point also uses dual or variable speed intake pumps to minimize flow
rates.
5. James A. Fitzpatrick The James A. Fitzpatrick Nuclear Station is equipped
with a submerged offshore velocity cap to reduce impingement.
Impingement at this facility was dominated by alewife and as further
protection for this species an acoustical fish deterrent (AFD) system was
installed, reducing alewife impingement by more than 90%. Fitzpatrick has
also added modified Ristroph screens.
6. Nine Mile Point Nuclear Power Station Unit 1 of the Nine Mile Point
Nuclear Generating Station is equipped with a submerged offshore velocity
cap to reduce impingement mortality. Unit 2 uses closed-cycle cooling.
7. Prairie Island Nuclear Power Plant Prairie Island employs use of 0.5 mm
fine mesh modified traveling water screens (low pressure wash, fish buckets,
continuous screen rotations and a fish return system) when entrainable fish
life stages are present from the beginning of April through the end of
August. Additionally, during these months the maximum through screen
velocity does not exceed 0.5 fps, providing a benefit to both impingeable fish.
8. Point Beach Nuclear Plant Point Beach installed a high frequency acoustic
deterrent system to reduce impingement of alewife, a dominant impingement
species.
9. Quad Cities Generating Station This facility engages in an aquaculture
program that raises walleye and hybrid striped bass for stocking in the
7-2
Mississippi River that mitigates impingement losses at the CWIS. As of

mid-January 2012, over 7 million fingerling walleye, 600,000 fingerling
hybrid striped bass, and nearly 70,000 yearling hybrid striped bass have raised
and stocked in the Mississippi River. In 2011 alligator gar were added to the
program.
10. R. E. Ginna Nuclear Station The R. E. Ginna Nuclear Station is equipped
with a submerged offshore velocity cap to reduce impingement mortality.
11. Salem Nuclear Power Plant Salems CWIS is equipped with enhanced
Ristroph-modified traveling screens with a fish return system. This
technology was identified as BTA for impingement in the proposed 316(b)
rule for impingement mortality reduction. Additionally, to offset CWIS
losses, some 20,000 acres of degraded salt marsh and adjacent uplands were
restored, enhanced or preserved, greatly increasing aquatic production in the
Delaware Estuary. Just three of the seven wetland restoration sites are
estimated to produce 3.9 times the secondary consumer biomass potentially
lost due to entrainment at the Salem CWIS. (Note 1)
12. Seabrook Station Seabrook is equipped with a submerged offshore velocity
cap to reduce impingement mortality.
13. St. Lucie Nuclear Power Plant St. Lucie is equipped with a submerged
offshore velocity cap to reduce impingement mortality. The facility has also
added a small mesh barrier net to prevent sea turtles from entering the intake
canal.
14. San Onofre Nuclear Generating Station (SONGS) Studies conducted in
California have demonstrated that SONGS has existing technologies that
reduce impingement mortality by an estimated 94.2% for finfish (97.7% by
weight). Impingement mortality reduction is achieved through the use of an
offshore intake with a velocity cap combined with an on-shore fish return
system (FRS). In addition to modifications to the intake structures, Southern
California Edison has committed to restore 150 acres of coastal wetland,
costing $86 million. This acreage was determined by the California Coastal
Commission (CCC) to be sufficient to offset entrainment losses of Units 2
and 3. Recent California regulations have required that all power plants
convert to closed-cycle cooling, but the two nuclear plants in California will
be subject to an independent, specific analysis of cost/benefit that is currently
being scoped. (Note 1)
Note 1: These plants use restoration or remediation strategies that replenish fish
stock lost via CWIS impacts. These strategies include construction of fish
hatcheries and/or natural spawning grounds such as marshes and wetlands.
However, as discussed in Chapter 2, the Second Circuit Court of Appeals
determined in 2007 that use of restoration measures could not be used as a
compliance option. The Supreme Court reversed other Second Circuit opinions,
but did not address the issue of restoration. Thus, EPA cannot consider
restoration as a compliance measure. Despite this, some states either require or
give credit for restoration activities.
7-3

Impingement Mortality
There are a variety of alternative fish protection technologies and operational
measures available to reduce impingement mortality. The practicality, cost, and
performance of these technologies tends to be very site specific, due to their
variability in terms of performance for species of concern, hydraulic conditions
and water depth in the vicinity of the intake, waterbody type and uses, and other
factors. A brief summary of technology categories is provided below, based on
details in Ref. 27.
7.2.1 Exclusion Technologies
Exclusion technologies function by keeping fish and other aquatic life from
entering the cooling water intake structure. This is accomplished by using a
combination of a physical barrier such as a screen and sufficient surface areas to
achieve a through screen velocity that does not exceed 0.5 fps. Examples include
use of cylindrical wedgewire screens or barrier nets. The same result can be
achieved with conventional traveling screens where there is sufficient screen
surface to maintain the through screen velocity below 0.5 fps. The barrier net is
generally the lowest cost exclusion technology, but it may have higher
maintenance costs. There are over a dozen deployments in the U.S. at fossil
facilities, but none at nuclear facilities. They are best suited for use in protected
waters such as freshwater lakes, reservoirs and tidal waters. Their primary
disadvantage is that they tend to be labor intensive and net changes may be
required twice per week in tidal waters to control biofouling. Due to deployment
in the source waterbody, navigation obstruction can also be an issue.
Wedgewire screens have been deployed at a number of fossil facilities and come
in a variety of sizes. They can be designed for offshore deployment on the bottom
of the source waterbody or from a bulkhead along the shoreline. The surface area
can be kept clean and free of biofouling through use of compressed air (airblast),
mechanical cleaning or manual cleaning. Major issues that may preclude
application at certain sites are lack of adequate water depth, high debris loading
(including frazil ice), low or varying ambient current velocity, navigation issues,
and open ocean deployment. Cylindrical wedgewire screens are also one of the
highest cost alternative fish protection technologies.
7.2.2 Fish Collection and Transfer Technologies
Fish collection and transfer technology was identified by the EPA as BTA for
impingement mortality reduction. The technology is based on use of
conventional traveling water screens that have been modified to maximize the
survival of fish and shellfish collected on the screens, and to transport them back
to the source waterbody to a location outside the zone of hydraulic influence of
the cooling water intake structure. Mortality is minimized by continually rotating
the screens and transferring collected fish to a fish return sluiceway, where they
can be returned to the source waterbody in as short a time as possible. There are a
variety of types of modified traveling screens, including Ristroph-modified
7-4
traditional band, Passavant-Geiger Rotary screen, Hydrolox molded polymer

screen, and Beaudry Water Intake Protection (WIP) vacuum screen.
Ristroph modified traditional band screens were the first screens developed with
fish protection characteristics and has been most widely used. Recently there has
been increased use of Passavant-Geiger Rotary screens as they also eliminate
carryover of debris that can cause condenser blockage. The Beaudry WIP
traveling screens are unique in that fish are vacuumed off the screens while
underwater and transported with a Hidrostal fish pump back to the source
waterbody. EPRI studies at Omaha Public Power Districts North Omaha
Station (EPRI Technical Report 10184900; Ref. 28) found the technology had
very high survival rates, with no significant difference in survival between the test
organisms and controls.
There are two other design concepts that have undergone laboratory testing and
have the potential to significantly reduce impingement mortality. These are the
modular inclined screen (MIS) and AquaSweep system. The MIS consists of a
flat panel wedgewire screen inclined at a 15 degree angle in an intake tunnel.
While cooling water passes through the 2 mm screen, fish and shellfish are
carried up the inclined panel and collected into a fish collection pipe where flow
provided by a Hidrostal fish pump transports them back to the source waterbody.
This technology avoids the need for fish to be impinged on traveling screens for
collection.
AquaSweep consists of a single vertical flat panel wedgewire screen placed in
front of the cooling water intake structure and perpendicular to the cooling water
flow. River flow in the case of facilities located on free flowing rivers or induced
flow generated by a large fish friendly pump, generate a flow parallel to the flat
panel wedgewire screen that exceeds the flow velocity through the flat panel
screen. The result is that impingeable sized organisms are transported past the
flat panel wedgewire screen rather than being impinged on it.
7.2.3 Velocity Caps
There are currently six nuclear power plants equipped with velocity caps which
have been shown to significantly reduce impingement mortality. They work by
generating a flow field that many species of fish can detect and then avoid. In
California there are six facilities with velocity caps, one of which is nuclear, and
they have the capability to reverse flow to control biofouling in the intake
tunnels. The discharge pipes are open pipes without velocity caps. Studies were
done to compare impingement rates from withdrawing water through the open
discharge pipe to withdrawing water through the velocity cap. The most recent
such study conducted at the Scattergood Generating Station in 2006/2007
demonstrated greater than 95% reduction in impingement mortality with the
velocity cap. Earlier studies at three other California coastal facilities had
impingement reduction results ranging from 53 to 99%.
7-5
7.2.4 Velocity Reduction

EPRI conducted a study [Ref. 29] of the relationship of approach velocity and
fish swim speeds. Figure 7-1 summarizes the results of 536 independent data
points of studies conducted for various fish species and size ranges in response to
velocity. The results show that at a through screen velocity of 0.5 fps (approach
velocity of 0.25 fps) there is only one data point below the threshold, suggesting
that a through screen velocity of 0.5 fps is highly protective for all impingeable
species and life stages. EPRI also found that for facilities that impinge larger size
ranges, a higher through screen velocity could provide equally protective results.
Further, these data indicate that, in general, reducing velocity reduces the
potential for impingement.
Figure 7-1
Critical fish swim speeds relative to water velocity based on 536 data points for
various fish species and size ranges. (Ref. 29)
7.2.5 Fish Diversion Systems

Diversion systems have also been shown to be an effective means for reducing
impingement for many fish species. As noted above, the Brunswick Nuclear
Station employs a diversion system at the entrance to the intake canal that,
combined with modified traveling screens and a fish return, have reduced
impingement by more than 90%.
7.2.6 Flow Reduction
An EPRI study of the relationship between flow and potential for aquatic
impacts (EPRI 2003; Ref. 30) conducted by the Oak Ridge National Laboratory
did not find a clear dose-response relationship between flow withdrawals and the
status of fish populations. However, the EPA, in the Phase II Rule, stated that
7-6
reducing intake flow by installing flow reduction technologies will result in a similarly
high reduction of impinged and entrained organisms. (Federal Register Vol. 69, No.
131, pg. 41612). EPRI did find that a reduction in flow through an existing
intake will also result in a reduction in velocity; and there is a clear relationship
between a reduction in velocity and a reduction in impingement. While dry or
closed-cycle cooling achieves the greatest reduction in flow, there are two other
methods used to reduce flow. Both of these methods involve reducing the flow
during non-peak generation times. The first technique is to reduce the number of
cooling water pumps in operation and the second is to install variable speed
drives on the pump motors that can achieve a greater level of control for flow
reduction. Unfortunately, nuclear facilities are baseloaded and there is a direct
relationship between cooling water flow and generation capacity. As a result
there is little opportunity to make any significant reduction in flow at nuclear
plants using these methods.
7.2.7 Behavioral Devices
Behavioral devices, such as use of sound or light, tend to be effective only on a
species-specific and seasonal basis. In general, sound is most effective for species
such as alosids that have an air bladder. Both the James R. Fitzpatrick and Point
Beach Nuclear Plants have used acoustic fish deterrents (AFDs) effectively to
reduce the impingement of alewife that was the dominant impinged fish species.
The Fitzpatrick AFD was demonstrated to reduce alewife impingement in excess
of 90%.
7.2.8 Change in Intake Location
Although very site-specific, there are instances where relocation of the intake
structures has achieved significant reduction in impingement. One is in the Great
Lakes, where fish tend to be most abundant along the shoreline and in near shore
areas. Locating the entrance to the intake offshore in colder deeper water and/or
using an offshore velocity cap can result in reduced fish impingement. This is
also true on the West Coast where the water depth drops off quickly due to the
relatively short distance to the continental shelf. Withdrawing colder deeper
water can also reduce the amount of cooling water needed and improve unit
efficiency.
Entrainment Mortality
Due to the small size and more fragile nature of entrainable life stages, and the
amount of water required for once-through cooling, reducing entrainment
mortality is significantly more challenging than reducing impingement mortality.
However, there are a number of options that may be practical to reduce
entrainment losses based on the same factors discussed for impingement
mortality reduction. The categories of options are similar to those listed for
impingement mortality reduction; however, the options are more limited since
most entrainable life stages tend to behave as passive water particles. As a result,
behavioral devices and diversion systems which rely on a fish behavior response
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are ineffective. In general, flow reduction is not considered practical for nuclear
power plants, other than use of closed-cycle cooling, since nuclear facilities are
baseloaded. A short summary of the major categories of potential options is
provided below.
7.3.1 Exclusion Devices
Exclusion technologies for entrainment reduction include narrow-slot wedgewire
screens and the aquatic filter barrier (AFB). Narrow slot wedgewire screens are
the same as described under Section 7.2.1, however, the slot width is reduced to a
range from 0.5 mm to 2.0 mm depending on the entrainable life stages in the
vicinity of the intake. The AFB is essentially a sophisticated barrier net that
incorporates an airblast cleaning system to control biofouling and remove debris
that accumulates on the barrier. These technologies work by using a low
through-slot or mesh velocity that is equal to or less than 0.5 fps. The result is
that a significant amount of surface area is required to achieve the low velocity
and that may be problematic depending on the site. Currently, there are no
nuclear generating stations that use narrow slot wedgewire screens, and there has
only been a single fossil facility in the U.S. (i.e., Lovett Station which is now
retired) that has used an AFB. [Ref. 31] In general the AFB is not considered
practical for facilities located on the open ocean, in areas with significant
waterborne debris, or in areas where it could affect water navigation.
Opportunities for use at existing once-through cooled nuclear stations is expected
to be very limited due to the higher flow rates and the amount of cloth area that
would be needed.
Narrow-slot wedgewire screens, due to the variety of deployment options (i.e.
deployment offshore or from a bulkhead and a variety of module sizes) have
greater potential for use. Generally deployment for facilities on open oceans
would be extremely difficult due to the high biofouling rate in marine
environments and the limited capabilities of the airblast system to control that
fouling. Adequate depth is also a concern for this option. EPRI evaluated the
practicality of narrow-slot wedge-wire screens for the Monticello Nuclear
Generating Plant and it was estimated that some 224 two-foot diameter screen
modules would be required due to the shallow depth of the Mississippi River as it
flows by this facility.
7.3.2 Fish Collection and Transfer Technologies
Fish collection and transfer technologies are the same as described for
impingement mortality reduction. Ristroph-modified band screens, PassavantGeiger Rotary, Hydrolox molded polymer screen, and Beaudry WIP vacuum
screen all are manufactured in a fine-mesh screen version. Generally, most are
designed to fit into existing screen wells and tend to be the lowest cost fish
protection technology to reduce entrainment. However, as discussed for
impingement, performance varies greatly depending on the species of concern.
EPRI laboratory research has found that survival rates for the earliest entrainable
life stages (i.e., larvae less than 12 mm tail length) is very low as these life stages
have not yet developed scales and musculature to survive the impingement
7-8
process. Additionally, early life stages of more fragile species such as shad,
herring and bay anchovy have been found to generally have poor impingement
survival rates. Recreational species tend to be hardy and EPRI studies
documented relatively high survival rates for these species.
The MIS and AquaSweep design concepts discussed in Section 7.2.2 also have
potential for use to reduce entrainment mortality. The MIS is currently designed
with 2 mm slot width that is significantly smaller than the 9.5 mm mesh used on
conventional traveling screens and would collect and transfer larger entrainable
life stages. The flat panel AquaSweep wedgewire screen could be similarly
designed with narrower slot wedgewire that would allow entrainables to by-pass
the intake.
7.3.4 Change in Intake Location
There are several examples where relocation of the cooling water intakes has
achieved significant reduction in entrainment, but this option can be very sitespecific. The first is in the Great Lakes. For many of the lakes, the major
spawning tends to be along the shoreline such that locating the intake structure
offshore in deeper water results in a significant reduction in the number of
entrained organisms. A second example is depth. A new fossil facility (proposed
Bonnet Carre Generating Station) was approved under CWA Section 316(b)
Phase I, Track 2 (allows use of once-through cooling) after demonstrating the
equivalent of a 90% reduction in entrainment could be achieved by withdrawing
cooling water from the bottom of the lower Mississippi River due to the
significantly lower densities of entrainable life stages at those depths compared to
shoreline densities at the surface. [Ref. 32]
7.4 Summary of the Potential Use of Alternative Fish
Protection Technologies and Operational Measures for
Nuclear Power Plants
Approximately one third of the 39 existing once-through cooled nuclear
generating stations have already installed fish protection technologies and
operational measures, or have instituted environmental mitigation measures to
offset impingement and/or entrainment losses. There are additional fish
protection technologies that can potentially be deployed to further reduce
impingement mortality, and a more limited set of options that can potentially be
deployed to further reduce entrainment mortality. These alternate operational
measures and technologies may reduce the potential for adverse environmental
impact without increasing consumptive water use, and without the other
detriments associated with retrofitting closed-cycle cooling. Flow reductions,
other than use of closed-cycle cooling, are generally not considered practical for
nuclear facilities due to their continuous baseloaded operation.
7-9
Section 8: Summary and Conclusions

Since the 1980s, most new plants have been designed with closed-cycle cooling.
Three regulatory and/or policy drivers have affected this:
1. Concern for potential impacts of the heated water discharged back to the
source waterbody,
2. Impacts of the plants cooling water intake structures on fish and aquatic
organisms,
3. Freshwater availability, especially in arid regions of the U.S. or regions
without large waterbodies from which to withdraw cooling water.
The Clean Water Act regulates the first two of these drivers and has been a
major factor in the shift toward closed-cycle cooling over the last two to three
decades. In contrast, no federal regulations serve as a driver to manage the
consumptive use of water. As a result, state, regional and commercial interests are
most active in this area. As discussed in this report, managing competing
stakeholder interests for limited water resources is becoming increasingly
important, and efforts to coordinate among federal and state authorities can be
difficult.
The purpose of this report was to examine all three of these drivers together to
determine options for meeting these often competing goals. This report has
addressed the technological design details and various factors considered in
selecting once-through cooling vs. closed-cycle cooling technology systems for a
given site, with particular emphasis on nuclear plants. Choices of preferred
technologies are highly site-specific, which has led to a wide range of technical
alternatives, including mechanical cooling towers, hyperbolic cooling towers,
cooling ponds, dry cooling technologies, hybrid cooling systems that use both wet
and dry cooling, as well as a wide range of intake technologies and operational
measures to minimize potential impacts to aquatic life.
In general, closed-cycle cooling performs better in addressing drivers 1 and 2
above, and can address cooling needs for plants with insufficient water availability
for once-through cooling (driver 3), but has higher consumptive water usage.
Once-through cooling generally performs in reverse of these worse in
addressing drivers 1 and 2, but better in addressing driver 3. The end result,
balancing these potential environmental impacts, is highly dependent on the
specific features and environmental needs of a particular site and its source water
8-1
body. At each site, these three drivers may vary in importance depending upon
the makeup of the local ecology.
8.1 Consumptive Use of Water
The consumptive use of water is an important environmental issue, with major
strategic implications to several regions of the U.S. Water shortages and water
use conflicts are increasingly becoming major concerns in some parts of the U.S.
Increased demand by multiple water users is inevitable, and shortages are likely to
become more acute in coming decades. Competition over limited fresh water
resources may become increasingly intense in many regions of the U.S.
In general, currently available information indicates recirculating cooling
technologies consume at least twice as much water as once-through cooling
technologies. As such, converting existing once-through cooling facilities to
closed-cycle cooling has the potential to adversely affect water availability in
some regions of the U.S.
As discussed in Chapters 2 and 3, many fossil and nuclear units were designed
with closed cycle cooling to address thermal issues, especially ones sited on
smaller water bodies; and a number of once-through-cooled fossil facilities have
been required to retrofit with closed-cycle cooling to address these same thermal
issues. Managing consumptive water use at such sites during high temperature
and/or drought conditions is particularly challenging. Plant shutdowns or derates have proven necessary when plants approach thermal limits or when source
water body water levels drop too low to meet circulating water pump net suction
head requirements. Long term solutions for such sites may include:
Helper towers, as discussed in Section 2.3.3.
Reservoir enhancements to increase water storage capacity (e.g., dredging,

dam height increases)
Additional water storage in nearby storage ponds or reservoirs, topped off

during winter or spring and depleted as needed during summer months
Augmenting wet closed-cycle cooling with additional dry cooling capacity for
use in drought conditions (see Section 2.3.5 for this option at North Annas
planned new Unit 3).
8.2 Tying Together the Trade-offs into Three Categories

The following summary is assembled in three categories: current facilities, new
plants on existing sites, and new plants on new sites. The tradeoffs of closedcycle cooling and once-through cooling that have been presented earlier in this
report are factored into each of these three categories, in order to present the
practical implications.
Given the general trend toward closed-cycle cooling based on drivers 1 and 2, the
following discussion highlights instances where the relative importance of driver
8-2
3 at a particular site might favor once-through cooling in a balanced assessment

of options.
8.2.1 Existing Facilities
As discussed in Chapter 1, most thermoelectric generating facilities used oncethrough cooling prior to the 1970s. Regulatory initiatives, most notably the
CWA, resulted in increased use of closed-cycle cooling from the 1970s through
the 1980s. About 60% of currently operating nuclear plants in the U.S. use oncethrough cooling and 40% use closed-cycle cooling.
The issue for existing facilities relative to selecting once-through vs. closed-cycle
cooling is a central part of the proposed 316(b) rule: should existing oncethrough facilities be converted to closed-cycle cooling? Chapter 2 described the
proposed rule and options being considered by EPA. Chapter 6 summarized the
reports prepared by EPRI to address the complex environmental and economic
issues involved in this question, and the costs and benefits of retrofitting. EPRIs
analysis showed that on a national basis, the annualized cost of retrofitting the
nuclear facilities is about 800 times greater than the annual environmental
benefits of retrofitting. While this cost-benefit estimate comparison does not
include an economic estimate of non-use societal benefits, it also does not
include the willingness to pay to avoid the localized impacts associated with
closed-cycle cooling discussed in Section 4.4.
8.2.2 New Plants on Existing Sites
EPAs proposed rule imposes requirements for new plants on existing sites that
are substantially similar to the EPAs requirements for new plants as set forth its
2001 Phase I rule.
As discussed in Chapter 2, Option 1 in the proposed rule allows for flexibility on
the part of the permitting authority to consider a number of site-specific factors
that might influence a BTA decision, especially in the case of entrainment. For
example, a new plant on an existing site may be able to use once-through cooling
if it can demonstrate equivalent fish protection to closed-cycle cooling. However,
other factors that the permitting authority must consider have nothing to do with
fish protection. For example, if imposing closed-cycle cooling on an existing
plant would create serious problems with the consumptive use of water at a
particular site, then the permitting authority is allowed to consider that situation
in making the BTA decision (e.g., allowing once-through cooling, with other
BTA protections as appropriate to that site, to be designated as that sites BTA),
for the existing unit. However, in that instance, the permitting authority is not
allowed to come to that same conclusion for a new plant built on that same site,
because the once-through cooling option is only available for that site via a fish
protection criterion unrelated to consumptive use. Other limiting factors
unrelated to fish protection, such as particulate emissions in excess of Clean Air
Act requirements, could prevent closed-cycle cooling from being considered as
BTA for an existing plant, but the permitting authority is not allowed to come to
that same conclusion for a new plant on that same site one that could create the
8-3
same particulate emissions if closed-cycle cooling is imposed on that new plant.

Land use is another example of a limiting factor relevant to this decision, because
of the additional land requirements associated with installing cooling towers.
As discussed in Section 3.3.2, (note specifically the quote from EPAs proposed
rule), the 2001 Phase I rule envisioned that new units on existing sites would be
subject to existing facility regulations for that site. However, the proposed rule
for existing facilities reversed this, imposing Phase I regulations on new units on
existing sites. The implications of this change are unclear for facilities that lack
adequate space for closed-cycle cooling or that may be precluded from use of
closed-cycle cooling due to permitting issues. Further, the proposed rules
approach to new plants on existing sites is based on a rationale developed from
fossil plant trends. Fossil data analyzed in 2001 for the Phase I rule suggested
that only 24% of new coal capacity and only 12% of new combined cycle capacity
would be constructed on existing sites. However, as discussed in Chapter 3, the
U.S. nuclear industry will rely extensively on existing plant sites as the home for
additional nuclear reactor capacity. Roughly 60% to 80% of future nuclear
capacity is anticipated to be constructed on existing nuclear plant sites, based on
current trends. Thus, the proposed Phase II rule may have the effect of limiting
the number of new nuclear units that could be built on existing sites.
8.2.3 New Plants on New Sites
The basis for selecting closed-cycle cooling vs. once-through cooling for new
plants on new sites is established in EPAs 2001 Phase I rule. As discussed in
Chapter 2, the 2001 rule effectively establishes closed-cycle cooling as BTA for
new plants, with a Track 2 or demonstration track option that allows for an
alternate technology or a combination of technologies and operating methods
that reduce adverse environmental impact to a level comparable to closed-cycle
cooling. As discussed in Chapter 3, no construction permits for nuclear plants
have been issued for nuclear plants using once-through cooling since the late
1970s. No nuclear plants have exercised the Track 2 option, including all new
plants in the planning and licensing process.
Given growing concerns for future water use conflicts, there may be potential
situations or scenarios where the Track 2 option might be exercised for new
nuclear units. If so, the following research and data needs could better enable the
exercise of Track 2:
New plant sites where consumptive water use is a priority consideration.

There are regions of the U.S. where anticipated load growth will demand
additional generating capacity and where available water rights are fully
allocated and/or there is strong competition for remaining water resources. A
good example of this is in the upper Great Lakes region. Planners in this
region might consider the option of once-through cooling for new capacity
to help address regional issues with declining lake levels, using additional
BTA options such as best screen technology and/or deep water intakes as
necessary. Research that could reduce the risks, time delays and uncertainties
associated with the Track 2 option would benefit those planners.
8-4
New plant sites in Ocean/Estuary/Tidal River (O/E/TR) regions. This is a

more difficult situation for the possible use of once-through cooling, because
these O/E/TR regions typically have more stressed fisheries, and because
consumptive use of fresh water is not an issue in these regions. However, new
plant siting in these regions has an important indirect impact on the
consumptive use of water, because these plants can benefit from the
efficiency of once-through cooling without as large an impact on freshwater
consumption, theoretically reducing the number of new plants built on
freshwater sites.
As discussed in Chapter 5, the consumptive use of water has major strategic
implications to the U.S. and globally. Water shortages and water use
conflicts are already major concerns in some parts of the U.S. Increased
demand by multiple water users is anticipated, and shortages are expected to
become increasingly acute in coming decades.
As discussed in Chapter 3, the U.S. relies much more on fresh water for
nuclear plant cooling and less on saline waterbodies (i.e., oceans, estuaries,
and tidal rivers) than other nations, by over a factor of two. The data also
show that the U.S. relies much more on closed-cycle cooling and much less
on once-through cooling for its nuclear plants than other nations, by a factor
of about 1.7. Countries with geographic access to oceans preferentially site
thermoelectric plants at O/E/TR sites, if available, for thermoelectric plant
cooling, in large part to take advantage of the cooler water for efficiency
reasons, but also to preserve limited and valuable inland fresh water resources
for other water users (such as municipal water supply and agriculture).
As discussed in Chapter 6, not all nuclear units in O/E/TR environments
have significant issues with impingement and entrainment: thirteen units at
O/E/TR sites have been judged to have small environmental impacts.
Twelve of these 13 reactors use once-through cooling on O/E/TR sites. In
summary, NRC has determined, based on NEPA criteria, that over 60% of
reactors on O/E/TR sites that have been evaluated to date for license renewal
exhibit small environmental impacts.
The option of using once-through cooling for new plants at O/E/TR sites, as
a siting strategy to reduce consumptive use of fresh water, is available
through Track 2 of the Phase I rule. However, plant performance, reliability
and environmental complications as well as the added costs of using cooling
towers in saline environments serve as strong disincentives to power plant
siting in these regions. Significant technical and environmental analysis
would be necessary to implement selective use of once-through cooling in
these environments. Selective use of once-through cooling using Track 2 is
most feasible in O/E/TR regions where environmental impacts could be
smaller (e.g., areas with low migratory fish populations, sites conducive to
deep water intakes, sites in industrial areas or navigation channels). This
siting strategy could reduce new plant siting on fresh water bodies.
New plant sites in other regions with limited fresh water resources. Reliable
access to ample supplies of cooling water to current and future power plants
8-5
is very important to utilities. A broad range of technical solutions have been

developed, many with highly site-specific applicability. Among these are dry
cooling technologies and non-traditional water resources, such as:
-
Reclaimed or reprocessed water (e.g., municipal waste water treatment

effluent)
Saline aquifers and collector wells (poor quality groundwater)
Produced water from energy production (oil and gas wells, mine pool
water in abandoned coal mines, etc.)
Excess run-off from irrigation
Storm water
These options are increasingly being considered for new plants. For example,
new reactors planned for the Turkey Point site in Florida will use
Miami/Dade County municipal effluent for cooling water, eliminating the
need to use fresh water. This choice has the added advantage of helping the
State of Florida address salt water intrusion into inland regions of the state,
being driven by increased withdrawal of fresh surface water and groundwater
by public, industrial and agricultural users. Many of the other non-traditional
options listed above are being considered in the planning for new reactor
deployment in the U.S.
Other future strategies that can improve reliable access to ample supplies of
cooling water include increased use of cooling ponds, makeup water ponds
for drought mitigation, and reservoir preservation and expansion. The
feasibility of these strategies is highly site-specific and not generally available
for many new plant siting options. However, where applicable, they can
reduce water consumption (cooling ponds consume less water than cooling
towers), and provide greater assurance of reliable cooling water supplies
during drought conditions.
8.3 Key Conclusions
Water resources are critical to power generation. 98% of current electricity
generation requires water for cooling (fossil and nuclear power plants) or for
motive force (hydroelectric plants). Adequate water resources are becoming
problematic in many regions of the U.S., with competition among water users
expected to grow to critical levels in some regions of the U.S. Although utilities
can reasonably predict regional power demands and associated cooling water
needs 10-20 years into the future, it is very difficult for any plant owner to predict
today what the competing demands for water will be at a specific site for the full
life of that plant, especially nuclear plants with an anticipated lifespan in the
range of 60 to 80 years.
Nuclear energy can help fill the need for new generating capacity to help preserve
a diverse future supply of electricity. However, nuclear energy is faced with three
potential issues resulting from the CWA:
8-6
Increased concern over thermal discharges, especially in water constrained

areas or during summer months with high discharge temperatures or under
possible drought conditions.
Potential 316(b) requirements to retrofit existing once-through cooled

facilities with closed-cycle cooling, if designated as BTA. The costs
associated with retrofitting existing once-through-cooled nuclear plants were
estimated to be about $32 billion (and cost over $100 billion to retrofit both
nuclear and fossil plants) a cost that would be passed on to consumers in
the form of higher energy prices. For new plants, the CWA limits options
for possible use of once-through cooling.
Based on available information, closed cycle cooling consumes approximately

twice as much water as once-through cooling. This introduces the potential
for increased competition among freshwater-users on a regional basis for new
and existing generating facilities. Closed-cycle cooling could also create sitespecific issues relative to adequate water supplies for plants on cooling ponds
or small reservoirs.
Siting of new generation capacity will become increasingly challenging in the

decades ahead, as cooling water resources become more constrained, and as
available land for power plant siting becomes more limited. This will place
increased emphasis on the optimum utilization of existing fossil and nuclear sites,
with their established transmission access, water access, infrastructure for fuel
storage and handling, etc. For nuclear plants, existing sites provide the additional
advantages of assured safety and security capabilities (e.g., well-characterized
seismic safety performance).
There are alternative technologies to address impingement and entrainment
issues that could be sufficient to allow use of once-through cooling. Dry cooling
is especially problematic for nuclear power plants, but hybrid cooling may need to
be considered in certain water-challenged regions of the U.S. This approach,
although very costly, would minimize the safety and licensing consequences of
dry cooling.
8-7
Section 9: References
1. Running Dry at the Power Plant, EPRI Journal Article, Summer, 2007.
2. National Pollution Discharge Elimination System Cooling Water Intake
Structures at Existing Facilities and Phase I Facilities. USEPA, Federal
Register, Volume 76, Number 76, April 20, 2011.
3. Final Regulations to Establish Requirements for Cooling Water Intake
Structures at Phase II Existing Facilities, Final Rule. USEPA, Federal
Register, Volume 69, Number 131, July 9, 2004.
4. Cooling Water Issues and Opportunities at U.S. Nuclear Power Plants: A
Report to the U.S. Department of Energy, Office of Nuclear Energy
INL/EXT-10-20208, December 2010.
5. Cooling Water Options for New Generation of Nuclear Power Stations in
the U.K., SCH070015/SR3, Environment Agency. 2010.
6. Personal communication from John Maulbetsch, EPRI Consultant
7. Economic Evaluation of Alternative Cooling Technologies, EPRI
Report No. 1024805, Jan. 2012
8. Economic and Benefits Analysis for the Proposed Section 316(b)

9.
Phase II Existing Facilities Rule, EPA-821-R-02-001, February,

2002
Closed-Cycle Retrofit Study: Capital and Performance Cost Estimates,

(EPRI 1022491), EPRI, 2010.
10. Evaluation of the National Financial and Economic Impacts of a ClosedCycle Cooling Retrofit Requirement, (EPRI 1022751), EPRI, 2011.
11. Maintaining Electrical System Reliability Under a Closed-Cycle Cooling
Retrofit Requirement, (EPRI 1023174), EPRI, 2011.
12. Net Environmental and Social Effects of Retrofitting Power Plants with
Once-through Cooling to Closed-cycle Cooling, (EPRI 1022760), EPRI,
2011.
13. National Benefits of a Closed-cycle Cooling Retrofit Requirement (EPRI
1023401), EPRI 2011.
14. National and Regional Summary of Impingement and Entrainment of Fish
and Shellfish Based on an Industry Survey of Clean Water Act 316(b)
Characterization Studies, (EPRI 1019861), EPRI, 2011
9-1
15. An Investigation of Site-Specific Considerations for Retrofitting
Recirculating Cooling Towers at Existing Power Plants DOE;

Parsons Infrastructure and Technology Group, Inc. and the National
Energy Technology Laboratory (NETL), May, 2002
16. Diablo Canyon Power Plant; Cooling Tower Feasibility Study, Enercon
Service, Inc., March, 2009.
17. World Economic Forum (WEF) website:
http://www.weforum.org/en/index.htm.
18. Energy Demands on Water Resources: Report to Congress on the
Interdependency of Energy and Water, DOE, Dec. 2006.
19. Estimating Freshwater Needs to Meet Future Thermoelectric
Generation Requirements: 2011 Update, DOE-NETL-2011/1523,

NETL, September 30, 2011. Also, EMM Map available on DOEs
EIA website at:
http://www.eia.gov/forecasts/aeo/pdf/regional_maps.pdf
20. Water for Energy: Future Water Needs for Electricity in the Intermountain
West Pacific Institute, November 2011
21. Energys Water Demand: Trends, Vulnerabilities, and Management,
Congressional Research Service, January 2011
22. The Energy Challenge, Nature, M. Hightower, Sandia National Lab,
March 2008
23. A Review of Operational Water Consumption and Withdrawal Factors for
Electricity Generating Technologies, National Renewable Energy
Laboratory (NREL), March 2011.
24. Energy-Water Nexus: Improvements to Federal Water Use Data
Would Increase Understanding of Trends in Power Plant Water Use

GAO, October 2009
25. Water Use for Electricity Generation and other Sectors: Recent Changes
(1985-2005) and future Projections (2005-2030), EPRI Report 1023676,
November 2011
26. Do Power Plant Impingement and Entrainment Cause Adverse Changes in

Fish Populations? A Review of the Scientific Evidence. (EPRI Technical
Report 1023094), July 2011
27. Fish Protection at Cooling Water Intake Structures: A Technical
Reference Manual. EPRI Technical Update 1014934, December 2007
28. Beaudrey Screen Pilot-Scale Impingement Survival Study, EPRI Technical

Report 10184900, January, 2009.
29. Technical Evaluation of the Utility of Intake Approach Velocity as an
Indicator of Potential Adverse Environmental Impact Under Clean Water
Act Section 316(b), (EPRI Technical Report 1000731); EPRI, 2000
9-2
30. Evaluating the Effects of Power Plant Operations on Aquatic

Communities: Summary of Impingement Survival Studies (EPRI Report
1007821), EPRI, October 2003.
31. Intake System Evaluation and Desktop Study Technical
Memorandum 2A, Attachment A Supplemental Aquatic Filter

Barrier Information. Alden Research Laboratory, Inc., Reference
1481449/6.2.2, November 2007
32. Personal Communication from Mr. Jack Tramontano, URS
Corporation
9-3
Appendix A: U.S. Nuclear Reactor Listing,

by Unit and by USGS Water
Resource Region
A-1
Condenser
Flow Rate
(1000 gpm) RX Type /
(NUREGNSSS
1437)
Supplier
Summer
Capacity,
MWe
(NUREG1350)
Thermal
Output
MWth
Original /
Uprated
Operating
License Issued /
Expires (NUREG1350) [or COL
subm. date]
Reactor
Operator / Licensee
State Cooling Water Source
Cooling System Type
1. NEW ENGLAND REGION: 5 OPERATING REACTOR UNITS AT FOUR SITES
Seabrook
FPL Group
NH Atlantic Ocean
Once-Through
399 PWR-West. 1244
3411 / 3648 1990 / 2030 #
Pilgrim-1
Entergy Nuclear
MA Cape Cod Bay/Atlantic Ocean
Once-Through
311 BWR-GE
685
1998 /
1972 / 2012 #
Millstone-2
Dominion Generation
CT Niantic Bay/L.I. Sound/Atlantic
Once-Through
523 PWR-CE
822
2530 / 2700 1975 / 2035
Millstone-3
Dominion Generation
CT Niantic Bay/L.I. Sound/Atlantic
Once-Through
907 PWR-West. 1155
3411 /
1986 / 2045
Vermont Yankee
Entergy Nuclear
VT Vernon Pool on Connecticut River
O-T plus towers (mechanical)
366 BWR-GE
620
1593 / 1912
1973 / 2032
2. MID-ATLANTIC REGION: 19 OPERATING REACTOR UNITS AT ELEVEN SITES -- PLUS 3 NEW UNITS PLANNED (does not include new PSEG unit) (note: adjacent Salem & Hope Creek treated as two sites)
Indian Point-2
Entergy Nuclear
NY Hudson River
Once Through
840 PWR-West. 1020
2758 / 3216 1973 / 2013 #
Indian Point-3
Entergy Nuclear
NY Hudson River
Once Through
840 PWR-West. 1025
3025 / 3067 1976 / 2015 #
Susquehanna-1
PPL Susquehanna LLC
PA Susquehanna River
Tower (1; natural draft)
448 BWR-GE
1135
3293 / 3441 1982 / 2042
Susquehanna-2
PPL Susquehanna LLC
448 BWR-GE
1140
3293 / 3441 1983 / 2044
Bell Bend (one unit)
PPL Susquehanna LLC
Towers (2; natural draft)
EPR
~1600
COL: 10/2008
Limerick-1
Exelon Generation
PA Schuylkill River
450 BWR-GE
1134
3293 / 3458 1984 / 2024 #
Limerick-2
Exelon Generation
PA Schuylkill River
450 BWR-GE
1134
3293 / 3458 1989 / 2029 #
Peach Bottom-2
Exelon Generation
PA Conowingo Pond on Susquehanna
O-T (mech. towers available)
750 BWR-GE
1112
3293 / 3514 1973 / 2033
Peach Bottom-3
Exelon Generation
PA Conowingo Pond on Susquehanna
O-T (mech. towers available)
750 BWR-GE
1112
3293 / 3514 1974 / 2034
TMI-1
Exelon Generation
430 PWR-B&W
786
2535 / 2568
1974 / 2034
Oyster Creek
Exelon Generation
NJ Barnegat Bay
Once Through
480 BWR-GE
619
1930 /
1969 / 2029
Salem-1
PSEG Nuclear LLC
NJ Delaware River
Once Through
1100 PWR-West. 1174
3411 / 3459 1976 / 2036
Salem-2
PSEG Nuclear LLC
NJ Delaware River
Once Through
1100 PWR-West. 1130
3411 / 3459 1981 / 2040
Hope Creek
PSEG Nuclear LLC
NJ Delaware River
552 BWR-GE
1061
3293 / 3393 1986 / 2046
ESP: 5/2010
(new unit @ Salem/H.C.) PSEG Nuclear LLC
NJ Delaware River
TBD
TBD
ESP under rev.
Calvert Cliffs-1
Constellation Energy
MD Chesapeake Bay
Once Through
1200 PWR-CE
873
2560 / 2700 1974 / 2034
Calvert Cliffs-2
Constellation Energy
MD Chesapeake Bay
Once Through
1200 PWR-CE
862
2560 / 2700 1976 / 2036
Calvert Cliffs-3
UNISTAR/Constellation
MD Chesapeake Bay
1 mech tower w/plume abatement
EPR
~1600
COL: 3/2008
North Anna-1
Dominion Generation
VA Lake Anna (fed by N. Anna River)
Once Through
940 PWR-West.
924
2775 / 2893 1978 / 2038
North Anna-2
Dominion Generation
Once Through
940 PWR-West.
910
2775 / 2893 1980 / 2040
North Anna-3
Dominion Generation
Hybrid (wet/dry combo) tower
US-APWR
~1700
ESP issued
COL: 11/2007
Surry-1
Dominion Generation
VA James River
Once Through
840 PWR-West.
799
2441 / 2546 1972 / 2032
Surry-2
Dominion Generation
VA James River
Once Through
840 PWR-West.
799
2441 / 2546 1973 / 2033
3. SOUTH ATLANTIC-GULF REGION: 23 OPERATING REACTOR UNITS AT 13 SITES - PLUS 12 NEW UNITS PLANNED (Note: 15 total sites including Lee & Levy; doesn't include future Duke & Southern sites)
McGuire-1
Duke Energy
NC Lake Norman on Catawba River
Once Through
675 PWR-West. 1100
3411 /
1981 / 2041
McGuire-2
Duke Energy
NC Lake Norman on Catawba River
Once Through
675 PWR-West. 1100
3411 /
1983 / 2043
Catawba-1
Duke Energy
SC Lake Wylie on Catawba River
Towers (mechanical)
660 PWR-West. 1129
3411 /
1985 / 2043
Catawba-2
Duke Energy
SC Lake Wylie on Catawba River
Towers (mechanical)
660 PWR-West. 1129
3411 /
1986 / 2043
Oconee-1
Duke Energy
SC Lake Keowee (fed by Keowee & Little Rivers) Once Through
680 PWR-B&W
846
2568 /
1973 / 2033
Oconee-2
Duke Energy
680 PWR-B&W
846
2568 /
1973 / 2033
Oconee-3
Duke Energy
680 PWR-B&W
846
2568 /
1974 / 2034
William S. Lee-1
Duke Energy
SC Broad River
Towers (3; mechanical)
AP1000
~1150
COL: 12/2007
William S. Lee-2
Duke Energy
SC Broad River
AP1000
~1150
COL: 12/2007
(Davie County)
Duke Energy
NC
TBD
TBD
TBD
(Oconee County)
Duke Energy
SC
TBD
TBD
TBD
Harris-1
Progress Energy
NC Lake Harris (fed by Buckhorn Creek) Tower (1; natural draft)
483 PWR-West.
900
2775 / 2900 1987 / 2046
Harris-2
Progress Energy
NC Lake Harris (will raise level ~20 ft.)
AP1000
~1150
COL: 2/2008
Harris-3
Progress Energy
NC Lake Harris (will raise level ~20 ft.)
AP1000
~1150
COL: 2/2008
Robinson-2
Progress Energy
SC Lake Robinson on Black Creek
Once Through
482 PWR-West.
710
2200 / 2339 1970 / 2030
Brunswick-1
Progress Energy
NC Cape Fear River
Once Through
675 BWR-GE
938
2436 / 2923 1976 / 2036
Brunswick-2
Progress Energy
NC Cape Fear River
Once Through
675 BWR-GE
900
2436 / 2923 1974 / 2034
Summer-1
South Carolina E&G
SC Lake Monticello (drains to Broad River)
Once Through
485 PWR-West.
966
2775 / 2900 1982 / 2042
Summer-2
South Carolina E&G
Towers (mechanical)
AP1000
~1150 COL issuance sked. early 2012
Summer-3
South Carolina E&G
Towers (mechanical)
AP1000
Vogtle-1
Southern Nuclear
GA Savannah River
510 PWR-West. 1152
3411 / 3565
1987 / 2047
Vogtle-2
Southern Nuclear
GA Savannah River
510 PWR-West. 1149
3411 / 3565
1989 / 2049
Vogtle-3
Southern Nuclear
GA Savannah River
AP1000
Vogtle-4
Southern Nuclear
GA Savannah River
AP1000
Hatch-1
Southern Nuclear
GA Altamaha River
556 BWR-GE
876
2436 / 2763 1974 / 2034
Hatch-2
Southern Nuclear
GA Altamaha River
556 BWR-GE
883
2436 / 2763 1978 / 2038
Farley-1
Southern Nuclear
AL Chattahoochee River
635 PWR-West.
851
2652 / 2775 1977 / 2037
Farley-2
Southern Nuclear
AL Chattahoochee River
635 PWR-West.
860
2652 / 2775 1981 / 2041
(TBD)
Southern Nuclear
TBD TBD
TBD
COL: plan 2011
Crystal River-3
Progress Energy
FL Gulf of Mexico
Once Through
680 PWR-B&W
838
2544 /
1977 / 2016 #
Levy County-1
Progress Energy
FL Cross Florida Barge Canal (to Gulf)
Towers (mechanical)
AP1000
~1150
COL: 7/2008
Levy County-2
Progress Energy
FL Cross Florida Barge Canal (to Gulf)
Towers (mechanical)
AP1000
~1150
COL: 7/2008
St. Lucie-1
Florida Power & Light
FL Atlantic Ocean
Once Through
491 PWR-CE
839
2560 / 2700 1976 / 2036
St. Lucie-2
FL Atlantic Ocean
Once Through
491 PWR-CE
839
2560 / 2700 1983 / 2043
Turkey Point-3
FL closed canal system (off Biscayne Bay) Once Through
624 PWR-West.
693
2200 / 2300 1972 / 2032
Turkey Point-4
FL closed canal system (off Biscayne Bay) Once Through
624 PWR-West.
693
2200 / 2300 1973 / 2033
Turkey Point-6
FL Municipal effluent from Miami/Dade + saltwater from collector wells
AP1000
~1150
COL: 6/2009
Turkey Point-7
FL (Same)
Towers (mechanical; both units)
AP1000
~1150
COL: 6/2009
4. TENNESSEE REGION + OHIO REGION: 8 OPERATING REACTOR UNITS AT FOUR SITES -- PLUS 2 NEW UNITS COMPLETING CONST. (Note: 4 total sites; doesn't include Bellefonte, Clinch River, Piketon)
Beaver Valley-1
FirstEnergy Nuclear
PA Ohio River
480 PWR-West.
849
2652 / 2900 1976 / 2036
Beaver Valley-2
FirstEnergy Nuclear
PA Ohio River
480 PWR-West.
832
2652 / 2900
1987 / 2047
Browns Ferry-1
Tennessee Valley Authority AL Tennessee River
O-T + Helper Towers (mechanical)
630 BWR-GE
1065
3293 /
1973 / 2033
Browns Ferry-2
630 BWR-GE
1118
3293 / 3458 1974 / 2034
Browns Ferry-3
630 BWR-GE
1114
3293 / 3458 1976 / 2036
Sequoyah-1
Tennessee Valley Authority TN Chickamauga Lake on Tennessee River
O-T + Helper Tower (natural draft)
522 PWR-West. 1150
3411 / 3455 1980 / 2020
Sequoyah-2
O-T + Helper Tower (natural draft)
522 PWR-West. 1127
3411 / 3455 1981 / 2021
Watts Bar-1
410 PWR-West. 1166
3411 / 3459 1996 / 2035
PWR-West. ~1180
const. restart '07
Watts Bar-2 (complete) Tennessee Valley Authority TN Chickamauga Lake on Tennessee River
Bellefonte-1 (complete) Tennessee Valley Authority AL Guntersville Lake on Tennessee River
410 PWR-B&W ~1250 const. restart OK'd by Board, 2011
AP1000
~1150
COL: 10/2007
Bellefonte-3
Tennessee Valley Authority
AL Guntersville Lake on Tennessee River
Bellefonte-4
Tennessee Valley Authority
AL Guntersville Lake on Tennessee River
AP1000
~1150
COL: 10/2007
Clinch River
Tennessee Valley Authority TN Clinch River
TBD
6 mPower units (B&W) ~6 X 125
TBD
Piketon
So. Ohio Clean Energy Park Allian OH Scioto River
TBD
TBD
TBD
A-3
Appendix B: U.S. Nuclear Reactor Listing,

by Site and by Site
Situation/Cooling Method
B-1
Total number of U.S. Sites: 68

(this number includes all currently operating plant sites, plus planned sites for new plants for which a COL or ESP application has been filed.
Therefore, new sites without a COL or ESP application currently on file with NRC are not included below (Amarillo, Green River, Piketon, Clinch River, etc.)
This listing includes three "greenfield" sites based on COL applications (Levy, Lee, Bellefonte) and one "greenfield" site based on ESP application (Victoria County)
@: Source: NUREG-1437
PLANT SITE
USGS REGION
COOLING WATER SOURCE
ACRES@ INTAKE STRUCTURE@ DISCHARGE STRUCTURE @ COMMENTS
SITUATION #1A: SITE USES CLOSED (WET) COOLING TOWERS AT ALL UNITS ON THAT SITE (NATURAL DRAFT, MECHANICAL, OR COMBINATION) [Note 1]
diffuser 240 ft from bank
Susquehanna River
acreage does not include adjacent Bell Bend Site.
Susquehanna + Bell Bend Mid-Atlantic
1075 River bank
To river
Schuylkill River
consumption issues
Limerick
Mid-Atlantic
595 From river
At shoreline
Susquehanna River
TMI-1
Mid-Atlantic
472 At river bank
Edge of river
Hope Creek
Mid-Atlantic
Catawba
W.S. Lee
Harris
Vogtle
Hatch
Farley
Levy County
Beaver Valley
South Atlantic-Gulf Lake Wylie on Catawba River

South Atlantic-Gulf Broad River
Delaware River
South Atlantic-Gulf Lake Harris (on Buckhorn Creek)

South Atlantic-Gulf Savannah River
South Atlantic-Gulf Altamaha River
South Atlantic-Gulf Chattahoochee River
Co-located with Salem 1 & 2 (once-through); Hope Creek uses a

tower. NPDES permits treat Salem & H.C. as separate sites
At edge of lake; submerged Cove of lake

391 125 ft from shore
edge of lake intake for RL system cooling and submerged

intake for RN system cooling
10,744 Reservoir on creek

3169 At river bank
To reservoir
Lake level to be increased to support units 2&3
Near shoreline
2244 Edge of river

1850 River to storage pond
120 ft from shore

At river bank
auxiliary heat loads use once-through cooling
501 At river edge

At lake bank
1770
Intake channel
1500
487 Crib 3,300 ft from shore
At river edge
auxiliary heat loads use once-through cooling

draws limited once-through cooling from nearby fossil unit
during summer months (into Unit 2 cooling tower basin)
1120 At edge of lake

Submerged 3,000 ft off
954 shore
Multiport 2,250 ft off
1100 shore
500 Shoreline
50 acre Pond to lake
1398 On river bank

Collector wells
2100
3342 At river bank
Discharge to river
South Atlantic-Gulf
Watts Bar
Tennessee
Ohio River
Chickamauga Lake just below Watts
Bar Dam on Tennessee River
Bellefonte
Palisades
Fermi
Tennessee
Guntersville Lake on Tennessee River
Great Lakes
Lake Michigan
Great Lakes
Lake Erie
Davis Besse
Great Lakes
Lake Erie
Perry
Duane Arnold
Byron
Great Lakes
Lake Erie
Upper Mississippi
Cedar River
Upper Mississippi
Rock River
Grand Gulf
River Bend
Lower Mississippi
Wells adjacent to Mississippi River
Lower Mississippi
Mississippi River
Callaway
10 ft into river
740
Ohio
Missouri
Missouri River
Holding pond to lake

Submerged multi-port
diffuser
108-ft canal
Submerged 930 ft off shore
Diffuser 1,650 ft off shore
Canal to shoreline
consumption issues
Discharge via barge slip

Into river
From river
To river
900 feet from shoreline
3 mile pipe, to 175 ft from
3188
Unit 2, if re-instated, would draw from Missouri River alluvial

aquifer
Columbia
Pacific Northwest Columbia River
550
shore
Wastewater effluent from Phoenix
cost of water is potential issue after lic. renewal (>40 years)
Palo Verde
Lower Colorado
4050 35-mile underground pipe Evaporation ponds
NOTES: 24 sites in this situation. (22 existing sites, 2 new greenfield sites) Total existing reactors = 32 (+ NMP-2 & ANO-2 = 34) Total new Rx = 11 (includes WB-2 but not suspended COLAs (4))
Note 1: for sites with multiple units, with some units using once-through cooling and some units using closed cooling (towers), the site is listed below in the appropriate once-through category
Color code: New Plants are yellow (full row = greenfield, second column only = on existing site; light = not active COL). Plants with 60 year License Renewal are green (dark = LR complete; light = EIS only).
Sites without recent EIS (via COL or LR) are orange
SITUATION #1B SITE USES ONCE THROUGH COOLING ON A MAN-MADE COOLING POND THAT IS EXEMPT FROM CWA 316(b) (Pond Not Classified as "Waters of the U.S.")
Turkey Point
closed canal system off Biscayne

South Atlantic-Gulf Bay
La Salle (%)
Upper Mississippi
Cooling Lake (off Illinois River)
Braidwood (%)
Upper Mississippi
South Texas (%)
Texas Gulf
Braidwood Lake (off Kankakee River)

Cooling Res. with m/u fm Colorado
River
Cooling Lake with m/u fm
Guadalupe River
Intake canal and barge

24,000 canal
From cooling pond; m/u
3060 from river
At lake shore
4457
from cooling res.; m/u
12,350 from bank of river
4000 acre Canal system
Units 3/4 used closed canal system; units 6/7 will use Dade
County water treatment effluent
To cooling pond
Surface flume
to reservoir; m/u to bank of
river
Units 3&4 will use main cooling reservoir (MCR), with an

increased depth of ~2 feet
Victoria County
Texas Gulf
11,532
NOTES: 5 sites in this situation (4 existing sites, 1 greenfield site [ESP currently under review]). Note: ones marked (%) are considered cooling ponds by NRC (NUREG-1437). Note 2.
SITUATION #2: SITE USES ONCE-THROUGH COOLING ON A COOLING POND WITH MAKE-UP WATER FROM A SMALL RIVER WITH LOW FLOW
Lake shore
North Anna
Robinson (%)
Summer (%)
Dresden (%)
Clinton (%)
Comanche Peak
Mid-Atlantic
Lake Anna (fed by North Anna River)
South Atlantic-Gulf Lake Robinson on Black Creek

Dissipates heat to Lake Monticello;
South Atlantic-Gulf make-up from Parr Reservoir
Upper Mississippi
Cooling Lake (off Illinois River)
Clinton Lake (off Salt Creek)

Squaw Creek Reservoir/Lake
Granbury
Texas Gulf
Dissipates heat to Coffey County
Lake on Wolf Cr.; make-up from John
Arkansas-White-Red Redmond Res.
Upper Mississippi
Via 3400 acre cooling pond
18,643
5,000 Edge of lake
Intake at shoreline
2200
Canal from Kankakee River
2227
14,090 Shoreline of creek
Shore of reservoir
7699
Cooling lake
Units 1 & 2 use once-through; unit 3 will use a hybrid tower.

Acreage includes entire Lake + shoreline
4.2 mile canal
acreage includes lake plus shoreline

Unit 1 uses once-through; units 2 & 3 will use towers. Units
operate in conjunction with pumped storage
Cooling lake to Illinois River acreage includes 1274 acre cooling lake and spray canal; uses
Helper Towers
3-mile flume
Units 1 & 2 use once-through from Squaw Creek Res.; Units 3 &
Canal to reservoir
4 will use towers & get m/u fm Lake Granbury
Cooling lake to embayment
Discharge pond to lake
9818
Wolf Creek (%)
NOTES: 7 sites in this situation. Note: ones marked (%) are considered cooling ponds by NRC (NUREG-1437). Note 2.
NRC LR: I&E Moderate impact
Note 2: NRC defines Cooling Pond as "a man-made impoundment that does not impede the flow of a navigable system and that is used primarily to remove waste heat from condenser water prior to recirculating the
water back to the main condenser" (ORNL/NUREG/TM-226).
SITUATION #3: SITE USES ONCE-THROUGH COOLING ON A MULTI-PURPOSE RESERVOIR (in-line with source river)
Vermont Yankee
New England
Peach Bottom
Mid-Atlantic
Browns Ferry
Tennessee
Sequoyah
Tennessee
McGuire
Oconee
Vernon Pool behind Vernon Dam on

Connecticut River
Conowingo Pond behind Conowingo
Dam on Susquehanna River
Wheeler Reservoir behind Wheeler
Dam on Tennessee River
Chickamauga Lake on Tennessee

River
Lake Norman behind Cowans Ford
South Atlantic-Gulf Dam on Catawba River
Lake Keowee behind Keowee Dam
South Atlantic-Gulf (fed by Keowee & Little Rivers)
Dardanelle Reservoir on Arkansas
Arkansas-White-Red River
Edge of river
125
620
840
525
30,000
510
Aerating structure at edge of Uses mech. cooling towers in summer; avg. consumption <0.1%
river
in tower mode. Max consumption on hottest day is <1.5%
Small intake pond
5,000-ft canal to pond
Mech. cooling towers installed but not used (5 previously
used in summer, 3 now retained operable for contingency)
Uses mechanical "helper" towers during warm parts of year.
Diffuser pipes to river
In small river inlet via
Cannot operate totally in closed cycle mode.
skimmer wall & forebay
From lake via skimmer
To lake/river via diffuser
Uses natural draft towers as "helpers" during warmer months
for large portion of cooling; cannot operate totally in closed
wall & forebay
pipes
cycle mode. Auxiliary heat loads use once-through cooling
capability to mix hypolimnetic water with surface water for
Submerged and surface at 2,000-ft canal discharge
cooling
shoreline
hypolimnetic water exclusively used for cooling. Units
710-ft deep skimmer wall 765 ft deep
operate in conjunction with pumped storage.
3220-ft canal
520-ft canal
Unit 1 uses once-through; unit 2 uses a tower
Arkansas Nuclear One

1160
NOTES: 7 sites in this situation.
SITUATION #4: SITE USES ONCE THROUGH COOLING ON AN OCEAN OR BAY OPEN TO THE OCEAN
Seabrook
New England
Atlantic Ocean
Pilgrim
Millstone
Crystal River
St. Lucie
Diablo Canyon
New England
Cape Cod Bay/Atlantic Ocean
New England
Niantic Bay/Long Is. Sound/Atlantic
South Atlantic-Gulf Gulf of Mexico

South Atlantic-Gulf Atlantic Ocean
California
Pacific Ocean
San Onofre
California
Pacific Ocean
3 deep structures, 7,000 ft diffuser, 5,500 ft off shore

896 off shore
Edge of bay (protected by 850-ft canal
517 breakwater)
Via holding pond
500 Niantic Bay
4738 16,000ft from shore
1132 1,200 ft off shore
750 At shore with break wall
velocity cap 3,400 ft off
84 shore
SITUATION #5: SITE USES ONCE-THROUGH COOLING ON AN ESTUARY OR TIDAL RIVER

Hudson River
Indian Point
Mid-Atlantic
239 At river bank
Oyster Creek
Salem
Mid-Atlantic
Mid-Atlantic
Barnegat Bay
Delaware River
Chesapeake Bay
Mid-Atlantic
Calvert Cliffs
James River
Mid-Atlantic
Surry
Brunswick
South Atlantic-Gulf Cape Fear River
Forked River from bay

1416 (reverse flow)
Edge of river
740
560 ft from shore
2070
840 1.7-mile canal
1200 3-mile canal from river
13,000ft canal

acreage includes fossil units
1,200 ft. & 3000 ft. off shore

Surface to ocean
3,800 to 8,500 ft from shore
Channel to river
NRC LR: I&E Moderate impact; NPDES treats units as separate
Oyster Creek to bay

500 ft into river
850 ft from shore

Co-located with Hope Creek (uses a tower). NPDES permits
treat Salem & Hope Creek as separate sites
Units 1 & 2 use once-through; unit 3 will use a mechanical
tower with plume abatement
2900-ft canal
6-mile canal to Atlantic
SITUATION #6: SITE USES ONCE-THROUGH COOLING ON A LARGE FRESHWATER RIVER (free-flowing)
Canal
Monticello
Upper Mississippi
Mississippi River
2150
Prairie Island
Upper Mississippi
Quad Cities
Upper Mississippi
Ft. Calhoun
Missouri
Cooper
Missouri
Waterford
Lower Mississippi
Mississippi River
560
Mississippi River
784 Edge of river

660 At shore
Short canal
Missouri River
Missouri River
Mississippi River
Uses mechanical "helper" towers during warm parts of year.

Cannot operate in total closed cycle mode.
Basin to towers and/or river Uses mechanical "helper" towers during warm parts of year.
Cannot operate in total closed cycle mode.
14,000-ft spray canal
Canal
At shore
1359 At shoreline
3561 At river bank
At shoreline
<5% mean annual river flow
At river bank
acreage includes fossil units
1,750 ft from shore, 22 ft.

908 deep
2065 1,750 ft from shore
At shoreline
SITUATION #7: SITE USES ONCE-THROUGH COOLING ON A GREAT LAKE

Kewaunee
Point Beach
DC Cook
Great Lakes
Lake Michigan
Great Lakes
Lake Michigan
Great Lakes
Lake Michigan
Ginna
Fitzpatrick
Great Lakes
Lake Ontario
Great Lakes
Lake Ontario
1,250 ft from shore

650 2,250 ft from shore
Lake bottom, 3100 ft. from Open canal
488 shore
To lake, ~1150 ft. from shore
702 ~850 ft. from shore
Nine Mile Point
Great Lakes
Lake Ontario
900
2 Flumes 150 ft from shore
Pipelines 1,000 ft off shore 555 ft. long diffuser pipe
B-3
Unit 1 uses once-through; unit 2 uses a natural draft tower;

unit 3 will use a mechanical tower
Appendix C: Summary Tabulation of

Number of NPPs in Each
Situation (per App. B)
C-1
Summary of EPA 316(b) Proposed Rule Applicability by Site and Unit

COUNT BY SITE
COUNT BY INDIVIDUAL UNIT
ALL SITES:
OPERATING NEW PLANT OPERATING +
NEW PLANT
NPPs ONLY
SITES
SITUATION
NEW PLANTS
(Greenfield +
existing site)
OPERATING
NPPs ONLY
ALL SITES:
OPERATING +
NEW PLANT
1A All units on site (both existing and new) use closed cycle cooling towers (based
on cooling towers) 100% of the time
22
(*) 2
25
($) 34
(&) 11
45
(**) 1
12
26
39
65
29
39
68
($) 42
62
* 104
(&) 15
(%) 7
(&) 22
57
69
126
1B Once through cooling on a man-made cooling pond that is exempt from 316(b)
(not "waters of the U.S."), making it effectively a CCC site ##
Total CCC sites and reactors (Situations 1A + 1B)
At least one unit on site uses once-through cooling 100% of the time.
TOTALS
($) includes
ANO-2 & NMP-2
(*) 3 new greenfield sites (COLs)

(**) 1 new greenfield site (ESP)
(&) includes
(%) these 7 new
Watts Bar-2 & units will use CCC
Bellefonte-1
on existing OTC site
Breakdown of "Once Through sites" (Situations 2-7))

2
3
4
5
6
7
Once-through on cooling pond with makeup from a small river with low flow ##
(includes two cat 3 units at one site, and 3 cat 2 site, each with new units)
Once-through on a multi-purpose reservoir (includes 6 cat 3 units on 3 sites, and
one Cat 2 site with one O-T unit and one CCC unit)
Once-through on ocean site (all cat 4)
Once-through on estuary or tidal river (includes one cat 2 site [new unit])
Once through on a large freshwater river (all Cat 4)
Once through on Great Lake (includes one cat 2 site with an O-T unit, an
operating CCC unit and a new CCC unit)
TOTALS
10
15
7
7
6
6
0
0
0
0
7
7
6
6
14
11
11
8
0
0
1
0
14
11
12
8
6
39
0
0
6
39
8
62
1
(%) 7
9
69
NOTES:
OPERATING PLANTS:
Only currently operating plants with a full power operating license are listed (no shutdown plants)
Adjacent plants NMP and Fitzpatrick considered separate sites because of different ownership and licensees
Adjacent Salem and Hope Creek units operated by PSEG considered separate sites because of different ownership history
Once-through site & unit listings include 12 reactors on 6 sites with helper towers that augment OTC during summer months
NEW PLANTS
Only new plants with a COL or ESP application currently on file with NRC are included in this data (i.e., Clinton-2, Piketon, Amarillo, Green River, etc. are not included)
New units with their COLA reviews suspended at NRC are not included (e.g., Callaway-2, Grand Gulf-3, River Bend-3)
This listing considers the following new sites to be "greenfield" based on COLAs: Lee and Levy; and Victoria Station based on ESP application.
This listing considers adjacent Susquehanna (operating) and Bell Bend (planned) to be on the same site. All other new units on existing sites are obvious
Completion of Watts Bar-2 is included with new plants. Planned future completion of Bellefonte 1 is not included in data
## Note that these units on a man-made cooling pond are effectively closed cycle systems equivalent to cooling tower technology for purposes of 316(b).
C-3
Appendix D: International Application of

Once-Through Cooling vs.
D-1
Country
Saline Water
Saline Water
(O/E/TR)
(O/E/TR)
Fresh Water
Fresh Water
Closed cycle Closed cycle Once-through Once-through
cooling
cooling
cooling
cooling
Total reactor
units
Argentina
Armenia
Belgium
Brazil
Bulgaria
Canada
17
18
China, mainland
13
14
Czech Republic
Finland
France
32
18
58
Germany
10
17
Hungary
India
18
Japan
55
55
Korea RO (South)
20
20
Mexico
Netherlands
Pakistan
Romania
Russian Federation
25
32
Slovak Republic
Slovenia
South Africa
Spain
Sweden
10
10
Switzerland
Taiwan
Ukraine
11
15
United Kingdom
19
19
Non-US Subtotal
80
89
168
337
USA-East Coast (1)
16
12
18
47
USA-Great Lakes (2)
13
USA-Central (3)
16
20
36
USA-Western (4)
41
40
22
104
121
129
190
441
USA-TOTALS
GLOBAL TOTALS
USA DATA BY USGS WATER RESOURCES REGIONS:

(1) New England, Mid-Atlantic, South Atlantic-Gulf
(2) Great Lakes region
(3) Ohio, Tennessee, Upper Mississippi, Lower Mississippi, Missouri, Arkansas-White-Red, Texas Gulf
(4) Lower Colorado, Pacific Northwest, California
non-US totals, by %
US totals, by %
Fresh Water
Closed cycle
cooling
24%
39%
Saline Water
Saline Water
(O/E/TR)
(O/E/TR)
Fresh Water
Closed cycle Once-through Once-through
cooling
cooling
cooling
0%
26%
50%
1%
39%
21%
D-3
Appendix E: EPRI National Cost Estimate

for Retrofit of U.S. Power
Plants with Closed-Cycle
Cooling: Technical Brief
Clean Water Act Fish
Protection Issues
E-1
E-2
E-3
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Once-Through Cooling and Closed-Cycle

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Once-Through Cooling and Closed-Cycle

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Program on Technology Innovation: Tradeoffs

Between Once-Through Cooling and Closed-Cycle

2012 TECHNICAL REPORT

This document does NOT meet the requirements of

EPRI Project Manager

3420 Hillview Avenue

DISCLAIMER OF WARRANTIES AND LIMITATION OF LIABILITIES

The following organizations prepared this report:

This publication is a corporate

The Electric Power Research Institute (EPRI) has been investigating

be in excess of 32 billion dollars. Although cooling towers would

Water is essential for human existence, food production, sustainable

1. Concern for potential impacts of the heated water discharged

Once-through cooling and closed-cycle cooling technology

U.S. and international nuclear plant data on cooling system

Tradeoffs that should be considered in evaluating cooling system

Extensive research by the Electric Power Research Institute

impacts of widespread expansion of closed-cycle cooling on the

Estimated environmental impacts of once-through cooling on

Key findings and conclusions from this study include:

Due to a variety of factors discussed in this report, dry cooling is

The United States is anticipated to rely extensively on existing

Based on an EPRI study of fresh water withdrawals, existing

Based on the best data available, closed-cycle cooling

The proposed 316(b) rule for existing facilities developed by

Recent research by the National Energy Technology Laboratory

virtually all of these independent studies identified little or no

Nevertheless, EPRI has examined a wide range of commercially

There are opportunities for balancing the associated tradeoffs

New plants where consumptive use of water is a priority

New plants in O/E/TR regions. This is a more difficult

New plants that utilize cooling ponds or small reservoirs for

As cooling water resources become more constrained and as available

Section 4: Comparison of Closed-Cycle Cooling

Section 7: Use of Alternative Fish Protection

Appendix D: International Application of OnceThrough Cooling vs. Closed-Cycle

Water use and conservation in the electric power generation sector

Implications of alternative forms of generation to provide power in a carbon

Advanced cooling technologies

Impacts of impingement and entrainment and the cost and benefits of

Fish protection technologies, and

Costs, benefits and other impacts of retrofit of cooling towers to existing

waterbody. In recent decades, most new facilities have employed closed-cycle

Impacts of the cooling water intake structure as a result of impingement of

3. Freshwater availability, especially in arid regions of the U.S. or regions

Figure II-I. Estimated Freshwater Withdrawals by Sector, 2000

Chapter 2 provides background information on how water is used to generate

Closed-cycle Cooling - Closed-cycle (or recirculating) wet cooling systems are

From an environmental standpoint the greater height of the tower helps to

2.3.3 Helper Towers

2.3.4.1 Direct dry cooling

have a larger footprint than the comparable wet cooling tower

be significantly more expensive than the comparable wet cooling system

2.3.4.2 Indirect dry cooling

2.3.5 Hybrid Wet/Dry Cooling Towers

2.3.5.3 Hybrid (parallel wet/dry) cooling

Turbine output loss with increasing exhaust pressure: Steam turbines

Required reduction in steam flow to protect the turbine: The operation

2. Turbine design: Nuclear plant turbines suffer more from increased

manufacturer that offers a nuclear turbine design for extended or elevated

hypothetical accident scenarios, and might be significant enough to show up

2.6 Overview of the Clean Water Act Relative to Once-through

regulations were challenged by a number of environmental stakeholder

(BTA) in the case of entrainment (requirements for impingement mortality